Privacy Policy
CRÉDE PERFORMANCE LTD
PRIVACY POLICY
Introduction
Welcome to the Créde Performance Limited’s privacy policy.
Créde Performance Limited respects your privacy and is committed to protecting your personal data in accordance with our obligations under the General Data Protection Regulation ((EU) 2016/679) and the Data Protection Act 2018 (referred to in this privacy policy as “Data Protection Law”).
This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
- Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Créde Performance Limited collects and processes your personal data through your use of our services and this website including any data you may provide through this website or by email or call when you avail of our service.
Our services or this website are not intended for children (anyone under 18) and we do not knowingly collect data relating to children.
Controller
Créde Performance Limited is the controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy policy).
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: Créde Performance Limited
Email address: crede@credeperformance.com
Telephone number: +353 86 348 0967
You have the right to make a complaint at any time to the Data Protection Commission (DPC), the Irish supervisory authority for data protection issues (https://www.dataprotection.ie/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
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
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 policy of every website you visit.
- The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, date of birth and gender.
- Contact Data includes address, email address and telephone numbers [and next-of-kin contact details].
- Financial Data includes bank account and payment card details.
- Technical Data includes 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 and our services.
- Transaction Data includes details about payments from you and other details of other services you may have availed of.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Technical Data to calculate the number of users in a specific territory or region.
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 policy.
Special Categories of Personal Data is personal data of a particularly sensitive nature, and includes information concerning a person’s health, sexual orientation, or their religious and philosophical beliefs. Due to the nature of our work, we may handle your health information and other special categories of personal data when carrying out our services and functions. For the purpose of this privacy policy, the types of personal data detailed in this paragraph are referred to as “Sensitive Data”.
Like all other types of personal data, we handle Sensitive Data when we have a lawful basis for doing so (as described in more detail in section 4 below) and strictly in compliance with all of our obligations under Data Protection Law.
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 (to provide our services to you). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
- How is your personal data collected?
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 phone, email or otherwise. This includes personal data you provide when you:
- apply for our services such as requesting a clarity call or booking a coaching session;
- request marketing or further information to be sent to you;
- 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 [https://credeperformance.com/cookie-policy/] for further details.
- Third parties. We may receive personal data about you from certain third parties in circumstances including:
o Technical Data from analytics providers.
o Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- How we use your personal data
We will only use your personal data when we have a lawful basis to do so. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform a contract to deliver services to you.
- 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.
- Where we need to comply with a legal obligation.
- Where you have consented to us using your personal data for specified purposes.
Most commonly, we will use your Sensitive Data in the following circumstances:
- Where it is necessary for the purpose of delivering the service that we have agreed to provide to you.
- Where you have consented to us using your Sensitive Data for specified purposes.
- Where we deliver a contract to you as a health care professional. We operate under a strict code of confidentiality.
Where consent is the lawful basis we rely upon to handle your personal data, you may withdraw such consent at any time free of charge.
Please 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.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of 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 including basis of legitimate interest |
To register you as a new client | (a) Identity (b) Contact | Performance of a contract with you |
To respond to queries, schedule coaching sessions and provide support | (a) Identity (b) Contact | Performance of a contract with you |
To provide appropriate services and advice | (a) Identity (b) Contact (c) Sensitive data | (a)Performance of a contract with you (b) delivery of a contract to you as a health professional (c)consent |
To process and deliver our service: (a) Manage payments, fees and charges (b) Collect money owed to us | (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 and conditions or privacy policy (b) Asking you to leave a review | (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 monitor how clients use our services) |
To administer and protect our business and our 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.) (b) Necessary to comply with a legal obligation |
To deliver relevant 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) Marketing and Communications (e) Technical | Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our website, services, marketing, client relationships and experiences | (a) Technical
| Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Profile (e) Marketing and Communications | Necessary for our legitimate interests (to develop our services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical 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 (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you orby contacting us 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 purchase of a service, warranty registration, service experience or other transactions.
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 [https://credeperformance.com/cookie-policy/].
- Disclosures of your personal data
We may share your personal data with third party service providers who perform services and functions at our direction and on our behalf. Such third-party services providers may include administrative service providers, accountants, legal advisers, IT service providers, payment service providers and security services providers engaged by us.
We may share your personal data with 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 policy.
We require all third parties to respect the confidentiality and 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 we only permit them to process your personal data for specified purposes and in accordance with our instructions.
Police force, government or quasi-government bodies, courts and tribunals
We may share your personal data with these organisations and bodies where we are required to do so by law.
- International transfers
We might transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as an area that provides for an equivalent level of protection for personal data as is provided for in the European Union. If, and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers. These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose by the European Commission. If you would like to receive further details of the measures that we have taken in this regard, please contact us at crede@credeperformance.com
- 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.
- Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period if we have a legitimate interest in retaining such information that is not outweighed by your fundamental rights and freedoms, where we have statutory or regulatory obligations to retain personal data for a longer period, or where we may need to retain the information in the event of a legal claim.
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.
- Your legal rights
You have a number of rights under data protection law in relation to how we use your personal data. These include the right, free of charge, to:
(a) Be informed about the personal data we hold about you and how we use that information.
(b) Obtain access to your personal data we hold.
(c) Have any personal data that we hold about you that you believe is incorrect, incomplete or inaccurate updated or corrected.
(d) Have your personal data erased.
(e) Have our processing of your personal data restricted.
(f) Object to our processing of your personal data.
(g) Request the transfer of your personal data to you or to a third party.
(h) Not be subject to wholly automated decisions, including profiling, which produce legal effects or which could have a similarly significant effect on you.
(i) Lodge a complaint with the Data Protection Commission.
These rights are in some circumstances limited by law. If you wish to exercise any of these rights, you can contact us using the details set out in section 1.
We endeavour to respond to all legitimate requests within one month. Occasionally it could 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.
- Updates
We may update this privacy policy from time to time. Any updates will be made available and, where appropriate, notified to you.