Privacy Policy
Last updated May 2021
Introduction
Forward Focus London is committed to protecting your personal information. It’s your
information, and we respect that. Our Privacy Policy gives you detailed information on
when and why we collect your personal information, how we use it and how we keep it
secure. This Policy also sets out your right to request that we delete, update, transfer or
provide you with access to your personal information. This Policy should be read
alongside our Terms & Conditions. Please also note that this Privacy Policy only applies
to personal information obtained by us in accordance with applicable laws – not
information collected from your interactions with third parties.
Who we are and how to contact us
The Sites (Website and App), and our Services (e.g. Coaching, Motivational Speaking,
Articles etc.) are operated by or on behalf of Forward Focus London Limited. If you
have any questions about this Privacy Policy or want to exercise your rights set out in
this Privacy Policy, please e-mail our Data Protection Officer at
dataprotectionofficer@forwardfocuslondon.com
If you are based in the EU, please continue to contact us at
dataprotectionofficer@forwardfocuslondon.com in the first instance.
Forward Focus London Limited is the data controller responsible for your
personal information and is registered at the UK Information Commissioner’s
Office with registration number: ZA694594
Forward Focus London Ltd. is an English company with registered company number:
11615250 and whose registered office is at 174 Coleherne Court, Redcliffe Gardens,
SW5 0DU, London.
How we collect your personal information
Generally, we collect your information when you decide to interact with us. This could
include purchasing a coaching session online, over the phone or in person when you
sign up to receive emails from us. We also look at how clients use our website, so that
we can offer the best possible experience.
We collect information in a number of ways, examples of which are listed below: ●
When you register or use forwardfocuslondon.com (the “Website”) ● When you
register or use the Forward Focus London App (the “App”) ● When you contact
Forward Focus by telephone or email or through electronic channels (e.g. the
website)
● When you sign up to receive marketing newsletters or follow a newsblog
● When you request to see a life coach
● When you attend workshops
● When you complete a client profile/client agreement/client waiver form;
● When you enter a competition, promotion or survey;
● When you give us some feedback.
● When completing any surveys that we send to you for research purposes
(although you are under no obligation to complete these)
● When completing any forms for transactional, employment or other purposes ●
When you visit our website: we use cookies to help make the experience of using
our website better and to personalise the service you receive from us – this means
we will remember your previous visits and track the pages on our website that you
visit. For more information please see our Cookie Policy. When you visit
www.forwardfocuslondon.com the Forward Focus London web server automatically
records your public internet protocol (‘IP’) address
● From time to time, we may also get data about you from third parties. This could
include other partners that provide some of our Services, such as Calendely,
Stripe, PayPal and EventBrite etc..
We may, with your prior written consent and signed waiver, also collect audio
recordings from your coaching sessions.
The types of information we collect
We only collect the information that’s necessary to carry out our business, provide the
particular service you’ve requested and to keep you up to date about all the latest
Forward Focus London news.
I. Information we obtain directly from you
Here are some examples of information we collect about you when you interact
with us:
○ Title
○ Name and Surname
○ Email address
○ Date of Birth
○ Contact phone number(s)
○ Purchase information
○ Interactions with us e.g. contacting our Customer Service, visitors logs,
testimonials
○ Payment details
○ Delivery address(s)
○ Billing address
○ Attendance at events
○ Appointment booking and information given during appointments (this may
include images and sensitive personal data)
○ Photograph
○ Official documentation providing proof of identification (photographic
identification) and related information provided on the official
documentation, including, where relevant, a passport number and driving
licence number
○ Automatically populated IP address*
○ Information from cookies**
*When visiting our website we may collect an automatically populated IP
address. An IP address is a unique number which allows a computer, group of
computers or other internet connected device (such as your mobile or tablet) to
browse the internet. We may also record the time and date of your visit, the
pages that were requested, the referring website (if provided) and your internet
browser version.
**For further information about Cookies and how Forward Focus London uses
them, please read our Cookie Policy.
We collect Special Categories of Personal Data about you (this includes details about
your health) as this is necessary for us to provide you with the best service. We do not
collect any other special category including information about criminal convictions and
offences.
If you fail to provide personal data where we need to collect personal data by law, or
under the terms of a contract we have with you and you fail to provide that data when
requested, we may not be able to perform the contract we have or are trying to enter
into with you (for example, to provide you with goods or services). In this case, we may
have to cancel the service you have with us but we will notify you if this is the case at
the time.
II. Information we obtain independently from you:
Your information may be shared with us by independent organisations, for example
other organisations that Forward Focus London has worked with. These independent
organisations will only do so when there is a lawful basis to do so. You should check
their Privacy Policy when you provide your information to them, to understand fully how
they will process and safeguard your data. These independent organisations may
include:
● Third Party Organisations
We may combine information you have given to us with additional information
made available from / shared with us by external sources. This will only be done
when we both have a lawful basis to do so.
● Information updates
From time to time we may screen our database against recognised data files,
such as the National Change of Address file, to help us keep our database up to
date.
● Social Media
Depending on your settings or the privacy policies for social media and
messaging services like Instagram,Signal,Facebook, Linkedin,WhatsApp or
Twitter, you may give us permission to access information from those
accounts or services. ● Information available publicly
We may include information found in places such as Companies House and
information that has been published in, for example, articles/ newspapers /
online.
Ensuring your personal information is only used where lawful
In order for our use of your personal information to comply with applicable data
protection law, that use by us needs to fall under at least one of the specific lawful
reasons that are set out in applicable data protection law. Examples of these lawful
reasons include our use of your personal information being necessary for the purchase
of services, or for compliance with a legal obligation.
Where your personal information is completely anonymised, we do not require a legal
basis to use it as the information will no longer constitute personal information that is
regulated under data protection laws. However, our collection and use of such
anonymised personal information may be subject to other laws where your consent is
required.
Where your personal information is not in an anonymous form, we will have a lawful
reason to use your personal information in such a way to ensure that we provide the
very best service to you and our other clients.
Where we need to comply with a legal or regulatory obligation, we will have a lawful
reason to use your personal information. For instance, we may be requested by the ICF
to provide notes or audio recordings or both from your coaching sessions to satisfy
certification requirements.
Why we collect your personal information and how we use it
We use information about you in a number of ways, including providing the services or
products that you have requested, offering you a personalised experience and informing
you about special speaking events or helpful workshops. We might also use the
information we have to contact you about any information we might need to process
your queries.
Examples of how we use your data are as follows:
To carry out our business and to provide a service or carry out a contract with you. ●
Process payments. Forward Focus London does not store any payment card
numbers once the transaction has been completed. We share your personal
information with credit card companies and other payment providers and acquirers.
These third parties will be responsible for the handling of your personal data for
these purposes and their privacy policies will set out how they do this. An example
of this is Stripe, who provide payment processing services for Forward Focus
London. They are a Data Controller of your transactional data in order to process
the payment. Stripe’s privacy statement, which can be found on their corporate
website, sets out how they use and handle your personal information.
● Contact you with important information relating to your booking or service, or use
and administration of any of our Services, such as confirming your booking.
Where we have your consent:
● Send you marketing updates via email about all the latest news, events and
offers concerning Forward Focus London. You can unsubscribe at any time by
clicking the unsubscribe link in any email. We share your personal information
with a variety of third party email marketing providers who assist us in delivering
our email marketing campaigns to you.
● Use your details to show you advertising on such Social Media platforms, such as
Facebook and Instagram, or via other third party advertising that may appear on
other websites you use. Online advertising channels we may use are: digital
display, video on demand, search engine marketing, paid social – these are all on
third party sites or platforms.
● We tailor emails and online advertising, so they’re relevant to your location and
what you have shown an interest in.
Where we have justifiable reason (legitimate interest):
● Respond to client enquiries raised online, in social media or on the phone.
● Invite you to provide feedback about our services in the form of online, email, or
phone surveys. We use this information to help us improve the quality of service
provided; to monitor the quality of our services and to assist with the selection of
future approaches to our products and services.
● To use data analytics to improve our website, products/services, marketing,
customer relationships and experiences
● To administer and protect our business and this website (including
troubleshooting, data analysis, testing, system maintenance, support, reporting
and hosting data)
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 get an explanation as to how the
processing for the new purpose is compatible with the original purpose, please contact
us dataprotectionofficer@forwardfocuslondon.com.
If we need to use your personal data for an unrelated purpose, we will notify you and we
will explain the legal basis which allows us to do so; however, you are entitled to object
to this new use of your data.
Sharing your information
We use third party platforms to manage and deliver customer relationship management
(CRM); some of our Services; email marketing campaigns; online advertising; customer
analytics; events; booking of appointments; cancellations; refunds; IT services; etc. In
providing the services, your personal information will, where applicable, be used by the
service provider on our behalf.
Examples of Third Parties include:
● Any affiliate of Forward Focus London Ltd.
● Our approved coaches, co-active coaching, counsellors, GOs, senior coaches
and the International Coaching Federation (ICF).
● Other third parties to whom we may choose to sell, transfer, or merge parts of our
business or our assets. Alternatively, we may seek to acquire other businesses or
merge with them. If a change happens to our business, then the new owners may
use your personal data in the same way as set out in this privacy notice.
● Service providers acting as processors based either in the UK or EEA who
provide IT and system administration, social media services, accounting,
invoicing and shipping services.
● Professional advisers acting as processors or joint controllers including, without
limitation, lawyers, bankers, auditors and insurers based either in the UK or EEA
who provide consultancy, banking, legal, insurance and accounting services.
● HM Revenue & Customs, regulators and other authorities acting as processors
or joint controllers based in the United Kingdom.
We will check any third party that we use to ensure that they can provide sufficient
guarantees regarding the confidentiality and security of your personal information. We
will have written contracts with them which provide assurances regarding the
protections that they will give to your personal information and their compliance with our
data security standards and international transfer restrictions.
Our use of cookies and similar technologies
Our website, app and emails contain certain cookies, pixels, records and other
technologies of which you should be aware. Please see our Cookie Policy.
Third Party Links and services
Our website, app and emails contain links to third party websites, tools and services.
Please remember that when you use a link to go from our Sites to another website, use
a third party tool or you request a service from a third party, this Privacy Policy no longer
applies.
Your browsing and interaction on any other websites, or your dealings with any other
third party tool or service provider, is subject to that website’s or third party tool or
service provider’s own rules and policies. We do not monitor, control, or endorse the
privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you
visit, or third party tool or service provider that you deal with, and to contact them if you
have any questions about their respective privacy policies and practices.
This Privacy Policy applies solely to personal information collected by us through our
Sites or Services (or Third Party providers performing our Services on our behalf) and
does not apply to these third party websites, tools and third party service providers.
Children
Customers need to be over 18 years old to create an account with us and to sign up to
receive our newsletter. We do not knowingly collect Personal Data from individuals
under the age of eighteen (18). If you are under the age of eighteen (18), please do not
submit any Personal Data through the Services. We encourage parents and legal
guardians to monitor their children’s Internet usage and to help enforce our Privacy
Policy by instructing their children never to provide Personal Data through the Sites and
Services without their permission. If you have reason to believe that a child under the
age of 18 has provided Personal Data to us through the Services, please email our Data
Protection Officer at dataprotectionofficer@forwardfocuslondon.com and we will
endeavour to delete that information from our databases.
How long do we keep your personal information for?
We keep your personal information in line with our company retention policy and as
required to comply with any legislation. We only retain information for as long as it is
required. For more information, please contact Forward Focus London’s Data Protection
Office at dataprotectionofficer@forwardfocuslondon.com.
Confidentiality and security of your personal information
We are committed to keeping the personal information you provide to us secure and we
will take reasonable precautions to protect your personal information from loss, misuse
or alteration. We do not sell your personal information for any purpose.
We have implemented information security policies, rules and technical measures to
protect the personal information that we have under our control from: ●
unauthorised access
● improper use or disclosure
● unauthorised modification
● unlawful destruction or accidental loss
All of our employees and data processors (i.e. those who process your personal
information on our behalf, for the purposes listed above), who have access to, and are
associated with the processing of personal information, are obliged to respect the
confidentiality of the personal information of all users of our Services.
How to access your information and your other rights
You have the following rights in relation to the personal information we hold about you:
Your right of access
If you ask us, we’ll confirm whether we’re processing your personal information and,
if so, provide you with a copy of that personal information (along with certain other
details). If you require additional copies, we may need to charge a reasonable fee.
Your right to correct information
If the personal information we hold about you is inaccurate or incomplete, you’re entitled
to have it corrected. If we’ve shared your personal information with others, we’ll let them
know about the changes where possible. If you ask us, where possible and lawful to do
so, we’ll also tell you who we’ve shared your personal information with so that you can
contact them directly.
Your right to delete information
You can ask us to delete or remove your personal information in some circumstances
such as where we no longer need it or if you withdraw your consent (where applicable).
If we’ve shared your personal information with others, we’ll let them know about the
erasure where possible. If you ask us, where it is possible and lawful for us to do so,
we’ll also tell you who we’ve shared your personal information with so that you can
contact them directly.
Your right to restrict information
You can ask us to ‘block’ or suppress the processing of your personal information in
certain circumstances such as where you contest the accuracy of that personal
information or you object to us processing it. It won’t stop us from storing your personal
information though. We’ll tell you before we lift any restriction. If we’ve shared your
personal information with others, we’ll let them know about the restriction where it is
possible for us to do so. If you ask us, where it is possible and lawful for us to do so,
we’ll also tell you who we’ve shared your personal information with so that you can
contact them directly.
Your right to data portability
With effect from 25 May 2018, you have the right, in certain circumstances, to obtain
personal information you’ve provided us with (in a structured, commonly used and
machine readable format) and to reuse it elsewhere or to ask us to transfer this to a
third party of your choice.
Your right to object
You can ask us to stop processing your personal information, and we will do so, if we
are:
(i) Relying on our own or someone else’s legitimate interests to process your personal
information, except if we can demonstrate compelling legal grounds for the
processing; or
(ii) Processing your personal information for direct marketing.
Your rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision when it’s based on automatic
processing, including profiling, if it produces a legal effect or similarly significantly affects
you, unless such profiling is necessary for entering into, or the performance of, a
contract between you and us.
Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your
personal information, you have the right to withdraw that consent at any time.
Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way
we’ve handled your personal information, you can report it to the UK Information
Commissioner’s Office (ICO). You can find details about how to do this on the ICO
website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123
1113.
California Privacy Supplement:
This California Privacy Supplement (“Supplement”) is in addition to the information
contained in the Forward Focus London Privacy Policy and applies to California
residents. We adopt this notice to comply with the California Consumer Privacy Act of
2018 (“CCPA”) and other related privacy laws. Any terms defined in the Privacy Policy or
in the CCPA have the same meaning when used in this supplement. Where any
individual interacts with Forward Focus London in relation to its products and/or
services, including, but not limited Forward Focus London websites, applications,
services and products, Forward Focus London may collect information on California
residents that identifies, relates to, describes, references, is capable of being associated
with, or could reasonably be linked, directly or indirectly, with a particular consumer or
device (“Personal Information”).
We may obtain data provided by Customer Data directly from individuals using Forward
Focus London products and services, including its websites or applications. Forward
Focus London may have collected the following categories of Personal Information from
consumers located in the State of California within the last twelve (12) months:
● Identifiers including names, mailing addresses, unique personal identifiers, ISP
addresses, account names, and other similar identifiers;
● Personal information under Cal. Civ. Code Sec. 1798.80 including names,
telephone numbers, account numbers, and other financial information of Forward
Focus London customers who have purchased goods or services;
● Commercial information such as products or services purchased, and purchasing
history; and
● Internet or similar network activity such as browsing history, search history, or
users’ interaction with Forward Focus London websites, apps, or ads.
Job applicants and employees
In addition to Personal Information set forth above, Forward Focus London also collects
information provided by job applicants and employees of Forward Focus London.
Forward Focus London has collected the following categories of Personal Information
from job applicants and employees located in the State of California within the last
twelve (12) months:
● Protected classification characteristics such as age, race, ancestry, national
origin, marital status, medical conditions, and veteran status; and
● Professional or employment related information including job history or
performance evaluations.
Job applicants and employees Forward Focus London does not collect biometric
information, geolocation data, audio, visual, thermal, olfactory or other sensory data,
educational records, non-public Family Education Rights and Privacy Act related data,
or inferences drawn from Personal Information.
Aggregated Data Personal Information does not include information that is de-identified
or aggregated, publicly available in government records, and information otherwise
excluded from CCPA’s scope including pursuant to the Fair Credit Reporting Act, the
Gramm-Leach-Bliley Act, the Health Insurance Portability and Accountability Act of
1996 (HIPAA) and other excluded state and federal laws.
Use of personal information Forward Focus London uses Personal Information as set
forth in the Forward Focus London Privacy Policy. Forward Focus London has not sold
the Personal Information of any California resident in the last 12 months.
Deletion requests (‘Right to Forget’) Forward Focus London complies with your rights
regarding your Personal Information, including the right to request deletion of your
Personal Information. Where Forward Focus London receives a validated request, and
Forward Focus London is not otherwise legally obligated to retain such Personal
Information, Forward Focus London will delete your Personal Information. Forward
Focus London may deny your deletion request where it is legally required to retain your
Personal Information, including as follows:
● Where Forward Focus London has a legal obligation to retain your Personal
Information, in conformity with state or federal laws that require the storage of
clinical records or professional board data retention requirements, and where
otherwise subject to state or federal law requiring the retention of data;
● Where it is necessary to protect you from unwanted data misuse, fraudulent
activity, or to maintain the security of data, data security, and in the protection of
data security incidents;
● Where retention of data by Forward Focus London is to comply with a legal or
contractual requirement to a Forward Focus London customer, such as a coach
who is required by coaching board rules to retain your Personal Information
related to your coaching records; and
● To make use of any Personal Information pursuant to other recognized
exceptions in the CCPA.
CCPA requests to access or delete Personal Information may be made by e-mailing
dataprotectionofficer@forwardfocuslondon.com. Only you or a person registered with
the California Secretary of State that you authorize to act on your behalf, may make a
verifiable consumer request related to your Personal Information. You may also make a
verifiable consumer request on behalf of your child. You may only request access or
deletion of Personal Information twice in any 12 month period. Your request must
contain a valid email address and describe within sufficient detail such that Forward
Focus London may evaluate and respond to such request. Forward Focus London will
not respond to requests without a verifiable email address. Making a request does not
require you to create an account, and Forward Focus London will only use information
in the request form to verify your authority to make the request and verify your identity.
Forward Focus London does not discriminate against anyone making a CCPA request,
and will not deny goods or services, charge different prices, or provide a different level
of quality of goods or services based on any CCPA request. Forward Focus London will
comply with the statutory time periods in which to respond to any CCPA request, and
where we require additional time to comply with a request, we shall communicate with
you on that request via email. We may also respond via email stating the reasons why
we cannot respond to your request, cannot verify you, or cannot comply with a request.
Where data is requested, Forward Focus London will select a format to provide a
response to allow you to transmit that information to another entity. Where requests are
deemed by Forward Focus London to be excessive, repetitive, or unfounded, Forward
Focus London may charge a fee for responding to your request.
About this supplement This Supplement applies to website visitors, coaching clients,
seminar attendees, application and product users, and other customers of Forward
Focus London Limited and its affiliated entities and business units in the United States.
Questions or comments? Contact us at dataprotectionofficer@forwardfocuslondon.com
or visit us at www.forwardfocuslondon.com
Changes to CA supplement Forward Focus London may change or amend this
supplement at any time, and any changes shall appear on the Forward Focus London
website at www.forwardfocuslondon.com.
Contact You may contact Forward Focus London about your rights under CCPA
at dataprotectionofficer@forwardfocuslondon.com
Changes to this Privacy Policy
We may make changes to this Privacy Policy from time to time. To ensure that you are
always aware of how we use your personal information, we will update this Privacy
Policy from time to time to reflect any changes to our use of your personal information.
We may also make changes as required, to comply with changes in applicable law or
regulatory requirements. We will notify you by e-mail of any significant changes.
However, we encourage you to review this Privacy Policy periodically to be informed of
how we use your personal information.
