Data Protection Notice

This is the privacy notice of the company “Philip Davies”, including the trading style of “Phil Davies Coaching and Consulting”. Reference to "I" and "my" relates to the company "Philip Davies".

This notice was last updated on 27 January 2025

Preserving the privacy and security of your data is of paramount importance to me, not just to comply with the letter of the law but also to meet the spirit and essence of what the law seeks to achieve – that you can be comfortable your data is safe.

Contact Details

Name: Philip Davies

E-mail: Phil@PhilDaviesCoaching.com

Introduction

This notice describes how I collect, store, transfer and use your personal data. It tells you about your privacy rights and how the law protects you.

In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information.

I am a Controller of your data. This means that I am choosing what data to collect and how it will be handled.

Wix.com is a Processor for your data when you visit this website. Zoho.eu is a Processor for your data if you email me @PhilDaviesCoaching.com. Acting in any way on personal data is referred to as ‘processing’. This means that Wix and Zoho will only process your data following your instructions and on your behalf. Wix.com state that they will not process your data for their own benefit. For more information about Wix’s obligations as a data processor for you, see their Data Processing Agreement for Wix customers. The Zoho privacy agreement is here: https://www.zoho.com/privacy.html

Except as set out below, I do not share, or sell, or disclose to a third party, any information collected through my website.

The type of personal information I collect

When you use my website, services or purchase from me, I ask you to provide personal data. This can be categorised into the following groups:

personal identifiers, such as your first and last names, your title and/or preferred pronouns
contact information, such as your email address, your telephone number and your postal addresses for billing, delivery and communication
account information, including your username and password
payment information, such as a debit or credit card number and expiry date and bank account details
records of communication between us including messages sent through my website, email messages and telephone conversations
marketing preferences that tell us what types of marketing you would like to receive
written notes from our conversations

By using my website and services, you consent that I may process some or all of:

your username and password and other information used to access the website and services
information you contribute, including reviews
your replies to blogs, polls and surveys
technical information about the hardware and the software you use to access the website and use my services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
usage information, including the frequency you use my services, the pages of the website that you visit, whether you receive messages from me and whether you reply to those messages
transaction information that includes the details of the products services you have bought from me and payments made for those services
your preferences to receive marketing from me; how you wish to communicate with me; and responses and actions in relation to your use of my services.

Use of aggregated information

I may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.

For example, I may aggregate usage information to assess whether a feature of the website is useful.

However, if I combine or connect aggregated information with your personal data so that it can identify you in any way, I treat the combined information as personal data, and it will be used in accordance with this privacy notice.

Special personal data

I do not collect any special personal data about you.

(Special personal data is data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. It also includes information about criminal convictions and offences)

How I obtain the personal information and why I have it

The information I process about you includes information:

you have directly provided to me
that I gather from third party databases and service providers
as a result of monitoring how you use the website or my services

The bases on which I process information about you

The UK General Data Protection Regulation (UK GDPR), requires me to determine under which of six defined bases I process different categories of your personal data, and to notify you of the basis for each category.

If a basis on which I process your personal data is no longer relevant then I shall immediately stop processing your data.

If the basis changes then if required by law I shall notify you of the change and of any new basis under which I have determined that I can continue to process your information.

Information I process because I have a contractual obligation with you

When you create an account on the website, buy a product or service from me, or otherwise agree to my terms and conditions, a contract is formed between you and me.

In order to carry out my obligations under that contract I must process the information you give me. Some of this information may be personal data.

I may use it in order to:

verify your identity for security purposes when you use my services
sell products to you
provide you with my services
provide you with suggestions and advice on products, services and how to obtain the most from using the website

I process this information on the basis there is a contract between us, or that you have requested I use the information before I enter into a legal contract.

I shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

Information I process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse the website or ask me to provide you more information about my business, including products and services, you provide your consent to me to process information that may be personal data.

Wherever possible, I aim to obtain your explicit consent to process this information, for example, I ask you to agree to the use of non-essential cookies when you access the website.

I continue to process your information on this basis until you 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 me using the contact details at the top of this page. However, if you do so, you may not be able to use the website or services further.

I aim to obtain and keep your consent to process your information. However, while I take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent me from continuing to process it. The law may allow me to continue to process your personal data, provided that there is another basis on which we may do so. For example, I may have a legal obligation to do so.

Information I process for the purposes of legitimate interests

I may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where I process your information on this basis, I do so after having given careful consideration to:

whether the same objective could be achieved through other means
whether processing (or not processing) might cause you harm
whether you would expect me to process your data, and whether you would, in the round, consider it reasonable to do so

For example, I may process your data on this basis for the purposes of:

improving my services
record-keeping for the proper and necessary administration of my business
responding to unsolicited communication from you to which I believe you would expect a response
preventing fraudulent use of my services
exercising my legal rights, including to detect and prevent fraud and to protect my intellectual property
insuring against or obtaining professional advice that is required to manage business risk
protecting your interests where I believe I have a duty to do so

Information I process because I have a legal obligation

Sometimes, I must process your information in order to comply with a statutory obligation.

For example, I may be required to give information to 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.

Information I process to protect vital interests

In situations where processing personal information is necessary to protect someone’s life, where consent is unable to be given and where other lawful bases are not appropriate, I may process personal information on the basis of vital interests.

For example, I may inform relevant organisations if I have a safeguarding concern about a vulnerable person.

How and when I process your personal data

Your personal data is not shared. Except for the circumstances of legal obligation or protecting vital interests detailed above, I do not share or disclose to a third party, any information collected through the website.

Information you provide openly on the website

If you leave a review or post a message on the website, I reasonably assume that you consent for the message to be seen by others. I may include your username with your message, and your message may contain information that is personal data.

Other examples include:

tagging an image
clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks

In posting personal data, it is up to you to satisfy yourself about the privacy level of every person who might use it.

I do not specifically use this information except to allow it to be displayed or shared. If it is provided then I may store it and I reserve a right to use it in the future in any way I decide.

Once your information enters the public domain, I have no control over what any individual third party may do with it. I accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for me to retain it, then at my discretion I may agree to your request to delete personal data that you have posted. You can make a request by contacting me using the details at the top of this page.

Payment information

At the point of payment, you are transferred to a secure page on the website of a reputable payment service provider. That page may be branded to look like a page on this website, but it is not controlled by me.

Direct Debit information

If you set up a Direct Debit arrangement, the information you give to me is passed to my bank for processing according to our instructions. I do not keep a separate copy.

Information obtained from third parties

Although I do not disclose your personal data to any third party (except as set out in this notice), I sometimes receive data that is indirectly made up from your personal data from third parties whose services I use.

No such information is personally identifiable to you.

Third party advertising on my website

Third parties may advertise on my 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 my 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.

I 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.

Service providers and business partners

I may share your personal data with businesses that provide services to me, or with business partners.

As examples:

I may pass your payment information to my payment service provider to take payments from you.

I may use fraud prevention agencies and credit reference agencies to verify your identity and I may pass your information to those agencies if I strongly suspect fraud on my website.

Use of information I collect through automated systems

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.

They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.

They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.

Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.

Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.

The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.

When you first visit my website, I ask you whether you wish to use cookies. If you choose not to accept them, I 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 may not be able to use all the functionality of our website.

The website is not intended to use any cookies other than essential ones. However, some applications may use cookies in the following ways:

to track how you use the website
to record whether you have seen specific messages I display on the website
to keep you signed in to the website, if you have signed in
to record your answers to surveys and questionnaires on our site while you complete them
to record the conversation thread during a live chat

Personal identifiers from your browsing activity

Requests by your web browser to my website’s servers at wix.com for web pages and other content on the website are recorded.

Wix.com may record information such as your geographical location, your Internet service provider and your IP address and that information is available to me. I also can access information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

I use this information in aggregate to assess the popularity of the webpages on the website and how I perform in providing content to you.

If combined with other information I know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to the website.

Re-marketing

I do not place such technology on my website, however applications from third parties may do so. Such activity is not within my control nor would I be party to any such information gathered or shared.

Encryption of data sent between us

Wix.com use Secure Sockets Layer (SSL) certificates to verify my identity to your browser and to encrypt any data you give me.

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.

Delivery of services using third party communication software

With your consent, I may communicate using software provided by a third party such as Facebook (WhatsApp), Zoho (email), Google (email, calendar), Apple (Facetime), Microsoft (Teams, Outlook) or Zoom Video Communications (Zoom).

Such methods of communication should secure your personal data using encryption and other technologies. The providers of such software should comply with all applicable privacy laws, rules, and regulations, including the GDPR.

If you have any concerns about using a particular software for communication, please tell me.

Data may be processed outside the UK

Wix.com can store your data in a number of locations. Your personal information may be stored in data centres located in the United States of America, Ireland, South Korea, Taiwan and Israel. Wix.com may use other jurisdictions as necessary for the proper delivery of their services and/or as may be required by law.

Wix.com is a global company that respects the laws of the jurisdictions it operates within. The processing of the User Customer Data may take place within the territory of the European Union, Israel or a third country, territory, or one or more specified sectors within that third country, of which, the European Commission has decided that it ensures an adequate level of protection (transfer on the basis of an adequacy decision).

Any transfer to a third country outside the European Union - which does not ensure an adequate level of protection according to the European Commission - will be undertaken in accordance with the current and updated set of Standard Contractual Clauses, as approved by the European Commission. These terms are set out in the Wix Data Processing Agreement (DPA).

The security of sensitive data is of extreme importance to Wix.com and they state they are 100% committed to data protection. See all the security certifications received by Wix.com.

Control over your own information

It is important that the personal data I hold about you is accurate and up to date. Please inform me if your personal data changes.

At any time, you may contact me to request that I provide you with the personal data I hold about you.

At any time you may review or update personally identifiable information that I hold about you, by signing in to your account on our website if you have created such an account.

To obtain a copy of any information that is not provided on the website you should contact me to make that request.

When I receive any request to access, edit or delete personal data I first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Please be aware that I am not obliged by law to provide you with all personal data I hold about you, and that if I do provide you with information, the law allows me to charge for such provision if doing so incurs costs for me. After receiving your request, I will tell you when I expect to provide you with the information, and whether I require any fee for providing it to you.

If you wish me to remove personally identifiable information from the website, you should contact me to make your request. This may limit the service we can provide to you.

I remind you that I am not obliged by law to delete your personal data or to stop processing it simply because you do not consent to me doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which I may process it, I may do so on that basis.

Communicating with me

When you contact me, whether by telephone, through the website, by email, by other electronic medium or in person, I collect the data you have given me in order to reply with the information you need.

I record your request and my reply in order to provide acceptable service.

I may keep personally identifiable information 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.

Complaining

If you are not happy with my privacy policy, or if you have any complaint, then you should tell me without delay.

If I receive a complaint, I record the information you have given on the basis of consent. I use that information to resolve your complaint.

I aim to investigate all complaints relating to user generated content on the website. However, I may not be able to do so as soon as a complaint is made. If I feel that it is justified or if I believe that the law requires me to do so, I shall remove the content while I do so.

Making a complaint may not result in the removal of the content. Ultimately, I have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

If I think your complaint is vexatious or without any basis, I may not correspond with you about it.

If your complaint reasonably requires me to notify some other person, I may decide to give to that other person some of the information contained in your complaint. I intend taking such action as a last resort and only where absolutely critical to finding a resolution to the complaint, but it is a matter for our sole discretion whether I do give information, and if I do, what that information is.

I may also compile statistics showing information obtained from this source to assess the level of service I provide, but not in a way that could identify you or any other person.

If a dispute is not settled then I hope you will agree to attempt to resolve it by engaging in good faith with me in a process of mediation or arbitration.

If you are in any way dissatisfied about how I process your personal data, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. I would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

My ICO registration reference is ZB562307

Retention period

Except as otherwise mentioned in this privacy notice, I keep your personal data only for as long as required by me;

to provide you with the services you have requested
to comply with other law, including for the period demanded by the tax authorities
to support a claim or defence in court

Compliance with the law

This privacy policy complies with the law in the United Kingdom known as the UK General Data Protection Regulation (UK GDPR), specifically the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’).

Review of this privacy policy

I shall update this privacy notice from time to time as necessary.