V1.0 Updated December 2020.
Cookie Policy
INFORMATION ABOUT OUR USE OF COOKIES
RebelKindly.com (“Our Website”) uses cookies to distinguish you from other users of Our Website. This helps us to provide you with a good experience when you browse Our Website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
- These are cookies that are required for the operation of Our Website. They include, for example, cookies that enable you to log into secure areas of Our Website or use the shopping cart.
- They allow us to recognise and count the number of visitors and to see how visitors move around Our Website when they are using it. This helps us to improve the way Our Website works, for example, by ensuring that users are finding what they are looking for easily.
- These are used to recognise you when you return to Our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
A number of cookies and similar technologies we use last only for the duration of your web session and expire when you close your browser. Others are used to remember you when you return to Our Website and will last for longer.
You can block cookies 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 Website.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit wikipedia.org, www.allaboutcookies.org, or www.aboutcookies.org.
Privacy Policy
Introduction
This is the privacy notice of Rebel Kindly Ltd.
We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.
1. WHO WE ARE AND IMPORTANT INFORMATION
What is the purpose of this privacy notice?
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you, for example, sign up to our newsletter, purchase a product or service or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Data controller(s)
Rebel Kindly Ltd is the controller and responsible for your personal data (collectively referred to as [“Rebel Kindly Ltd”], “we”, “us” or “our” in this privacy notice). Our contact details are our Registered Address at Suite 131, 41 Oxford St, Leamington Spa, Warks CV32 4RB, UK or Email us at AdminRebel@RebelKindly.com. For all data matters contact FAO Data Protection Officer on the address above.
Rebel Kindly Ltd is the controller and responsible for this website.
Changes to this Privacy Notice and your duty to inform us of changes
We keep this privacy policy under regular review. This version was last updated in December 2020. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links outside of our control
This website 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, we encourage you to read the privacy notice of every website you visit.
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity data (including your first name, last name, marital status, title, gender and multi-media images);
- Contact data (including your billing address, delivery address, email address, telephone contact numbers and social media contact information);
- Transaction Data (including details about payments to and from you and other details of products and services you have purchased from us).
- Technical Data (including internet protocol (IP) address, your login data, 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 you use to access this website).
- Profile data (includes your username and password, purchase history, preferences, feedback and survey responses);
- Usage Data (including information about how you use our website, products and services].
- Marketing and Communications data (including your preferences in receiving marketing from us and your communications preferences);
- Special Category Data (including dietary or access requirements when booking and attending events, information about your health or beliefs or opinions, race or ethnicity, sexual orientation)
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. for example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. however, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not generally collect any Special Categories of Personal Data about you (this includes details 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). Nor do we collect any information about criminal convictions and offences.
If you are a 1 to 1 Mentoring & Coaching Client, as part of the contract you will be required to sign a GDPR consent form to ensure your explicit consent for the processing of special categories of data. These may be discussed as part of our confidential 1 to 1 mentoring & coaching sessions with you and thus may be processed in order to perform our contract with you.
If you fail to provide personal data
Where we need to collect your 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 a product or service you have with us but we will notify you if this is the case at the time.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
Direct interactions.
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
- Schedule a chat to explore how we can help;
- Purchase a package from us;
- Subscribe to newsletter and email communication;
- Create an account on our website;
- Request information about Rebel Kindly services;
- Enter a competition, promotion or survey: or give us feedback or contact us.
Automated technologies or interactions.
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources.
We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers, such as Google based outside the EU;
- search information providers, such as Google based outside the EU;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- a. Where we need to perform a contract we are about to enter into or have entered into with you;
- b. 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;
- c. Where we need to comply with a legal obligation;
- d. Where we have received your informed and specific consent to do so.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that 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 contact us 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 in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing. |
| To register you as a 1 to 1 client, or subscriber to a course or newsletter | (a) Identity data (b) Contact data | (a) Performance of a contract with you |
| As a 1 to 1 client, to provide you with (a) tailored personalised support between mentoring/coaching sessions, (b) newsletter, emails and events | (a) Identity data (b) Contact data (c) Marketing and Communications data | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to ensure that we can support you between mentoring/coaching client sessions and provide a personalised high-value service) |
| As a newsletter subscriber, to provide you (a) Newsletters and emails with our information and inspiration, (b) news and offers on our services | (a) Identity data (b) Contact data (c) Marketing and Communications data | (a) Consent |
| As a 1 to 1 client, to process and deliver your services including: (a) Manage payments, fees and charges (b) Process your Service contract | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Special category data | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Explicit Consent (where special category data has been discussed in sessions) |
| As a course subscriber, to process and deliver your services including: (a) Manage payments, fees and charges (b) Process your Course contract | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To administer events and register you as an attendee or applicant | (a) Identity data (b) Contact data (c) Special category data | (a) Performance of a contract with you (b) Consent (where dietary and access requirements have been collected) |
| To enable you to partake in or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how members use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | (a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, events, customer relationships and experiences | (a) Technical | (a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
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 FAO Data Protection Officer at AdminRebel@RebelKindly.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. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting adminrebel@rebelkindly.com at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase or experience.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see above.
5. WHO WE SHARE YOUR PERSONAL DATA WITH
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.
We may disclose your personal information to third parties in the following circumstances:
- When a specific service is being provided on our behalf. We will ensure that your personal information is handled as if we were processing it ourselves and under the same terms as this privacy notice. We will only share the minimum information that they need to undertake the service and we will ensure that they keep your information secure.
- When you have requested information about a service or product provided by an affiliated partner and only with your specific consent.
- As required by HM Revenue & Customs, regulators and other authorities based in the United Kingdom.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
In general personal data collected from you will be stored at a destination within the UK or European Economic Area (EEA). However we may also transfer your data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries or organisations which have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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. 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, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for seven years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Your legal rights 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
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable 9i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact us at our registered address or via email AdminRebel@rebelkindly.com.
No fee required – with some exceptions
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 admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
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.
Time limit to respond
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. Changes to this notice and your duty to inform us of changes
This version was last updated on 4 December 2020.
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
11. Queries, requests or concerns
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our Data Protection Officer via email AdminRebel@rebelkindly.com.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK