Sanctus Privacy Policy

This Agreement is entered into by and between: Sanctus London Limited and “The Client” whereby Sanctus agrees to provide Sanctus Coaching for the Client within The Business.

Definitions

“The Client” — The individual attending a coaching session within “The Business”.

“The Business” — The employer providing Sanctus Coaching as a benefit to it’s employees (“Clients”)

“The Sanctus Coach” — The Coach providing Coaching Services via Sanctus.

“Sanctus” — the organization in relationship with The Business to provide the Sanctus Coach and their Coaching Services.

Nature of the relationship

Sanctus (Sanctus London Limited) holds a relationship with The Business to provide Sanctus Coaching to it’s staff.

Sanctus has a team of Sanctus Coaches who are self-employed contractors with Sanctus who deliver Sanctus Coaching within The Business.

Via Sanctus’ relationship with The Business, Sanctus Coaches offer coaching services to staff members (The Clients)

Introduction

1.1 We are committed to safeguarding the privacy of our clients

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our clients, in other words, where we determine the purposes and means of the processing of that personal data.

1.3 In this policy, “we”, “us” and “our” refer to Sanctus London Limited
Credit

2.1 This document was created using SEQ Legal (https://seqlegal.com).
How we use your personal data

3.1 In this Section 3 we have set out:
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 (a) the general categories of personal data that we may process;

 (b) the purposes for which we may process personal data; and

 (c) the legal bases of the processing.
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3.2 We may process data about your use of our services (“usage data”). The usage data may include information on your timing, frequency and pattern of your service use. Usage data is anonymised and will not include your personal details. The source of the usage data is our online Sanctus Booking System which is powered by Calendly, you can view their Privacy Policy here — https://calendly.com/privacy

This usage data may be processed for the purposes of analysing the use and frequency of use of Sanctus Coaching. The legal basis for this processing is consent and our legitimate interests in namely monitoring and improving our services specifically and mainly in discussions with The Business around overall usage of Sanctus.

3.3 We may process your account data (“account data”).The account data includes your name and email address. The source of the account data is from your booking via the Sanctus Online Booking System which is powered by Calendly (you can view their Privacy Policy above). The account data may be processed for the purposes of; a) The Coach communicating directly with you, b) Sending you relevant information regarding Sanctus Coaching, c) If our Coaches apply for coaching credentials and include their coaching hours with you (See Terms of Use section 6 on “Release of Information”). The legal basis for this processing is consent and our legitimate interests, namely the Coach receiving relevant credentials from their regulatory body for Coaching sessions conducted through Sanctus.

3.4 Where we have obtained specific consent from you, we may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services.

3.5 We may process information relating to our client relationships, including customer contact information and content data may be anonymously and hypothetically shared (“customer relationship data”). The customer relationship data may include your name, e-mail address and records of information contained in communications and discussions between you and The Coach within your sessions. The source of the customer relationship data is within the discussions between you and The Coach. The customer relationship data may be processed for the purposes of the Coaches training, supervision, mentoring, evaluation and for the Coaches professional development. The customer relationship data will will not be used by Sanctus or The Business for commercial purposes, as above the purpose is solely for the Coaches professional evaluation, integrity and safety. The legal basis for this processing is your consent by entering into our terms of use and our legitimate interests, namely the proper management, quality and safeguarding of Coaches and Clients.

3.6 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is explicit consent.

3.7 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website and e-mail provider (Google) will generate the metadata associated with communications. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and communications with users in responding to questions and queries.

3.8 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.9 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.10 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.11 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
Providing your personal data to others

4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

4.2 We may disclose your personal data to subprocessors insofar as necessary to provide our services.

4.3 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, coaching credentials with regulatory bodies, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 We will retain your personal data as follows:
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 (a) usage data will be retained for as long as it is required for the legitimate purposes of Sanctus’ business interests

 (b) account data will be retained for the duration of Sanctus’ relationship with The Business and for a period of 1 year after that relationship ends.

 (c) publication data will be retained until you notify us to remove it.

 (d) notification data will be retained until you explicitly change your notification settings.

 (f) correspondence data will be retained in accordance to an individuals personal record keeping.
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5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Amendments

6.1 We may update this policy from time to time by publishing a new version on our and within the Sanctus Online Booking System.

6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3 Where we have an on-going relationship with The Business, we will notify The Business of significant changes to this policy by email
Your rights

7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2 Your principal rights under data protection law are:
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 (a) the right to access;

 (b) the right to rectification;

 (c) the right to erasure;

 (d) the right to restrict processing;

 (e) the right to object to processing;

 (f) the right to data portability;

 (g) the right to complain to a supervisory authority; and

 (h) the right to withdraw consent.
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7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.

7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

7.10 To the extent that the legal basis for our processing of your personal data is:
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 (a) consent; or

 (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

 and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
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7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.13 You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section 7.
About cookies

8.1 Our website and apps use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and also allows us to improve the experience.

8.2 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.

Cookies that we use

9.1 We use the following cookies:

 9.1.1 **Strictly necessary 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.

 9.1.2 **Analytical/performance cookies.** 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.

 9.1.3 **Functionality cookies.** These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).

9.2 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 parts of our website.

9.3 Except for essential cookies, all cookies will expire after a period appropriate to their use.

Our details

10.1 This website is owned and operated by Sanctus

10.2 We are registered in England and Wales under registration number 10430289, and our registered office is at Rivington House, 82 Great Eastern St, London, EC2A 3JF.

10.3 Our principal place of business is at Rivington House, 82 Great Eastern St, London, EC2A 3JF.

10.4 You can contact us:
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(a) by post, to the postal address given above;

(b) using [email protected];
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