This Notice describes how your personal data is collected, processed and stored.
This Privacy Notice was drafted on 25th March 2019.
Touch of Clarity is the trading name of Claricel (Claz) Gomez, and your privacy is extremely important to me.
Your personal data is collected by Claz Gomez trading as Touch of Clarity, acting as data controller (ICO registration number ZA483470), henceforth recognised as “I” / “me/myself” / “my”.
Business address: GW Business Centre, Great West House 1, Great West Road, Brentford, TW8 9DF, United Kingdom.
Phone: +44 (0)20 84320987
This Privacy Notice covers this website and where this Privacy Notice is posted.
Data collection and usage
What type of information I have
I currently collect and process the following information:
- Personal identifiers, contacts and characteristics (for example, name and contact details)
- Sensitive personal data (as detailed below)
How I get the information and why I have it
Most of the personal information I collect, process, use and store is provided to me directly by you for the reasons as set out below. Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
(a) Your consent. You are able to remove your consent at any time. You can do this by contacting me using the contact information at the top of this page.
(b) I have a contractual obligation with you.
(c) I have a legal obligation.
(d) I have a vital interest.
(e) I have a legitimate interest.
The following table outlines what I do with the information you provide me and how I store your information. I operate a fully digital service, and as such, I do not retain paper records.
|What data I collect||Purpose and legal basis for processing your data||Where and for how long I store your data for|
|Personal data provided when booking any consultation with me, whether in person, on the phone or via any electronic means such as email and website. Such data includes:
Your phone number.
|Initiate interaction for future provision of service;
Provide a professional service;
Manage and administer my systems;
Communicate with you about my services (ie survey);
Improve my services;
|Personal data acquired for consultation purposes are stored on my account of the client management system Acuity Scheduling.
Should clients decide after a consultation call that they do not require services from me, their personal data will be deleted during the next data audit (max 6 months).
|Personal data provided when booking any change management or holistic therapy services with me, whether in person, on the phone or via any electronic means such as email and website. Such data includes:
Further data under the ‘special category’ of personal data may be collected if purchasing any coaching or holistic therapy service:
Data concerning personal lifestyle.
|Providing a professional service;
Fulfil contractual obligations;
Manage and administer my systems;
Communicate with you about my services;
Improve my services
|Personal data and Sensitive personal data is stored on my account of the client management system Acuity Scheduling.
For clients over the age of 18 at the time of contractual agreement, all data is stored for a minimum of 3 years and a maximum of 6 years after the last contact with the client.For clients under the age of 18 and any clients recognised legally as vulnerable adults at risk, records will be kept for 6 years after the last contact with the client unless any of the exemptions apply or if I am required to comply with any other statutory requirements.
|Audio recordings of sessions with minors and vulnerable adults at risk where a parent or legal guardian is not present during a session, as per contract.||Providing a professional service;
Fulfil contractual obligations;
Safeguard the minor and myself.
|For clients under the age of 18 as well as clients recognised by law as vulnerable adults at risk, audio recordings of the sessions are stored in a secure virtual space attributed to Touch of Clarity and will only be accessed to fulfull any statutory requirements. This data will be retained until my retirement age, or for 10 years if that is longer.|
|Data that you enter on our website when you share my web pages on your social media outlets:
Your social media account details/handle.
|Sharing your data with the third parties you have selected for the purposes of fulfilling your request for post-sharing and direct marketing if you have provided your consent to this.||This data is not retained by Touch of Clarity.|
|Data you provide when you register to receive my Clarity Club newsletters including:
Your email address;
Your friend’s name (if applicable);
Your friend’s email address (if applicable).
|Performance of a contract;
Sending you Clarity Club newsletters;
Making suggestions and recommendations to you about content, goods or services that may interest you;
Sending your friend a copy of the newsletter. We will only use the friend’s email address for this purpose unless they subsequently sign up for my Clarity Club newsletters.
|Consent (to receive direct marketing).
Where you use the “Forward to a friend” feature on my website or to send one of my newsletters to a friend, you must ensure that you have your friend’s permission to do so. I will only use your friend’s email address for this purpose and may inform your friend that you have requested this service.
|Data when we communicate with each other whether through my website or via email, in person or over the phone, through social media, on my blog or via any other medium, including:
Your contact details (this may include your social media account if that’s the way you communicate with me);
The details of your communications with me (including when you sent it, when we received it and where you sent it from (such as my website, via email, through social media));
Any videos, photographs or other content you provide;
Details of my messages to you.
|Performance of a contract;
Providing a professional service;
Answering any issues or concerns;
Monitoring client communications for quality and training purposes.
Developing new services which are based on the data provided;
Improving my services based on the data and feedback you provide and the information and feedback provided by others;
Notifying you of significant changes to my website.
Personalising my service to you taking into account of the data and feedback you have provided;
|If data has been collected into my email, it will be stored in my email inbox for up to 6 years maximum or for however long your records are retained following contractual fulfilment.
Any data collected verbally (in person or on the phone), may be stored in my client management system Acuity Scheduling for up to 6 years or for however long your records are retained following contractual fulfilment.
Any data shared publicly via my blog and social media portals will be retained permanently within those respective data mediums.
|Data that we collect through your use of my website including:
The type of browser you are using (e.g., Internet Explorer, Firefox, Safari, etc.);
The third party website from which your visit originated;
The operating system you are using (e.g., Vista, Windows XP, Mac OS, etc.);
The domain name of your Internet service provider;
The search terms you use on my website;
The specific web pages you visit;
The videos you view; and
The duration of your visits etc
|Providing and adapting my services to take account of the technical capabilities of my users and to ensure content is presented in the most effective manner;
Developing new services based on the data being collected, the behaviours of my users and the technical capabilities of my users;
Analysing site traffic and understand client needs and trends;
Improving my services to better suit the behaviours and technical capabilities of the users of my online mediums;
Identifying issues with the website and user’s experience of it;
Monitoring the way my website is used (including locations it is accessed from, devices it is accessed from, understanding peak usage times and analysing what functionality and information is most and least accessed).
|This data is held entirely within the Touch of Clarity website and is largely anonymous. The data is not removed or altered. In the case that your data is made anonymous and aggregated, the data will cease to be personal data.|
|Non-personal data that I collect regarding website use by analytic providers;
Data presented on my social media or wider social media platforms including Facebook, LinkedIn and Instagram;
|Maintaining market awareness; and
Building and maintaining social media branding.
|This data is held entirely within the reports (documents) and/or social media mediums. This data is largely anonymous and is deleted upon release of the next analytical piece. In the case that your data is made anonymous and aggregated, the data will cease to be personal data.|
Your personal data may be processed if it is necessary on reasonable request by a law enforcement or regulatory authority (e.g. the Police), body or agency, in the defence of a legal claim or in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety and wellbeing of any person, or violations of any of my terms of contract. Relevant personal data needed for an investigation or a dispute will not be deleted. It will continue to be stored until those issues are fully resolved.
Use of Data Processors
Touch of Clarity is heavily reliant on other data processors in order to provide you with an efficient and professional service. Every effort has been made to partner with third parties who incorporate the GDPR into their own data protection policies and actively prove their command of the security of my clients’ data. It is intended that the data you provide them through the use of my website be connected with the performance of their function. They will not be permitted to use your data for any purposes other than those outlined in this Privacy Notice unless you have consented to this with the data processor yourself. You must therefore ensure that you have read through their data privacy and protection policy when entering your data into their portals. In agreeing to my services, you agree that these data processors are by default the means with which I:
- a) schedule and book sessions with you
- b) raise and send you invoices
- c) process your payments for my services
- d) communicate with you
In addition, you consent to these data processors processing your information in order to fulfil your contractual obligations with me.
In agreeing to any coaching and/or holistic therapy service with me, you consent to your data being transferred and stored outside the European Economic Area (“EEA”). To ensure your personal data is properly protected in line with EU and UK data protection law, the transfer of this data is governed by a contract including Standard Contractual Clauses (SCCs) approved by the European Commission in accordance with Article 46(2)(c) of the General Data Protection Regulation. I will only transfer data to jurisdictions outside the scope of the European General Data Protection Regulation (GDPR) where the appropriate safeguards set out in the GDPR are in place by the data processor. If you would like to obtain copies of the regulator-approved SSCs please contact us on the contact details below.
Below is a list of the data processors I use, along with the links to their data protection policies.
|Data Processor||Location||Data Privacy / Protection policy|
|Microsoft Office 365 / Microsoft Cloud||US||https://www.microsoft.com/en-us/trustcenter/privacy/gdpr/gdpr-faqs|
We have no control over third parties’ websites and resources and accept no responsibility for them or for any loss or damage that may arise from your use of them.
Your data protection rights
Under data protection law, your data protection rights include:
Your right of access – You have the right to ask me for copies of your personal information as you are entitled to have a record of your information (including client notes).
Your right to rectification – You have the right to ask me to rectify information you think is inaccurate. You also have the right to ask me to complete information you think is incomplete.
Your right to erasure – You have the right to ask me to erase, remove or delete your personal information in certain circumstances. It is as easy for you to remove your information as it was to put it there in the first instance.
Your right to restriction of processing – You have the right to ask me to restrict the processing of your information.
Your right to object to processing – You have the right to object to the processing of your personal data.
Your right to data portability – You have the right to ask that I transfer the information you gave us to another organisation, or to you.
You are not required to pay any charge for exercising your rights. If you make a request, I have up to 30 days to respond to you and a further 14 days to action your request.
If you would like to exercise, or discuss your right to object or restrict the processing of your personal data please contact me at email@example.com, (+44) 0208 4320987 and/or Touch of Clarity, GW Business Centre, Great West House 1, Great West Road, Brentford, TW8 9DF.
You also have a right to file a complaint with the UK’s supervisory authority, the ICO, if you are unhappy with how I have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
You can opt-out of receiving direct marketing from me at any time by contacting me or clicking the ‘unsubscribe’ button on all marketing email.
Analysis and Cookies
Cookies help me to identify your browser or device. They collect and store data when you visit my website about how you use it and provide helpful information about your browsing behaviour. You may opt-out at any time from the collection and use of your data via cookies by contacting me above.
I’m committed to keeping your personal data safe. In trusting that my partners have put physical, technical and administrative measures in place to prevent unauthorised access or use of your data, I have endeavoured to satisfy all reasonable expectations concerning your data privacy. Please note that no data transmission or storage can be guaranteed to be 100% secure.
Changes to this Notice
This notice will be changed from time to time.
If I change anything important about this notice (the data I collect, how I use it or why) I will provide a prominent link to it for a reasonable length of time following the change on the website.