Privacy Policy
1. We at Kirk Miller Online Training Limited take your privacy seriously. This policy covers the collection, processing and other use of personal data under the Data Protection Act 1998 (“DPA”) and the General Data Protection Regulations (“GDPR”). This privacy policy applies to Kirk Miller Online Training Limited’s website at www.kirkmiller.co.uk (the “Website”) and in the provision of services by Kirk miller Online Training Limited (the “Services”).
2. For the purpose of the DPA and GDPR we are the data controller and any enquiry regarding the collection or processing of your data should be addressed to Kirk Miller Customer Relations- Privacy Policy at our email address info@kirkmiller.co.uk or in writing to our registered office address: Kirk Miller Customer Relations-Privacy Policy, Flat 16, Ormonde Court, 10-14 Belsize Grove, London, England, NW3 4UP
3. By using the Services and this Website, you consent to this policy. We are registered with the Information Commissioner’s Office for this purpose.
Information we collect
4. We will collect personal data through this Website and in the provision of our Services where this information is directly provided to us by you the user, e.g. your e-mail address, name, home or work address, details concerning your level of health and fitness, nutrition/ food logs, job role, relationship status and lifestyle, and any information contained in communications between us, and therefore has been provided by you with your consent.
5. We will collect data relating to your use of and adherence to our training programme and services “performance data” in order that we can fulfil our service agreement with you.
6. We may ask that you provide periodic personal photographic/ video updates to us in the provision of our services. This information is provided by you with your consent.
7. We process information relating to transactions, including purchases of Services and received payments for the purposes of our accounting and customer relationship management (transaction data). Your payment information (e.g. credit card details) provided by you in purchasing a subscription for use of our is processed securely and privately by third-party payment processors. We may share your personal data with our payment processors, but only for the purpose of completing the relevant payment transaction. Such payment processors are banned from using your personal data, except to provide these necessary payments to us, and they are required to maintain the confidentiality of your personal data and payment information.
8. We also use analytical and statistical tools that monitor details of your visits to our website and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data (but this data will not identify you personally).
9. We may collect any of the above personal information from third parties and publicly available sources, including:
(i) where you have authorised us to do so
(ii) an agent or third party acting on your behalf
(ii) publicly available third party sources such as LinkedIn, company websites, social media and news reports;
(iii) referring sources
Use of your information
10. We may hold and process personal data that you provide to us in accordance with the DPA and GDPR.
11. The information that we collect and store relating to you is primarily used to enable us to provide our Services to you, and to meet our contractual commitments to you. In addition, we may use the information for the following purposes:
11.1 To notify you about any changes to our Service or Website, such as improvements or service/product changes, that may affect our service;
11.2 If you are an existing customer, we may contact you with information about goods and services similar to those that were the subject of a previous sale to you;
11.3 Where you have consented to receive such information, to provide information on other parties’ products or services that we feel may be of interest to you;
11.4 Where you have consented to receive our e-newsletters, from time to time to provide that to you.
12. At times, we may also use your personal data for marketing and profiling. Where appropriate and practicable, we will seek your consent before undertaking some of these activities.
Disclosure of your information
13. We may disclose your information to regulatory bodies to enable us to comply with the law and to assist fraud protection and minimise credit risk.
14. Where you have consented for us to do so, we may provide your data to selected third-parties who may contact you about their goods or services that you may be interested in.
15. We may share your data with third party service providers who perform functions on our behalf in order that we fulfil our service agreement with you (including external consultants, business associates and professional advisers such as administrators, accountants, technical support functions and IT consultants);
16. If you do not want us to use your data for our [or third-parties’] use, you will have the opportunity to withhold your consent to this when you provide your details to us on the form on which we collect your data, or you can do so by sending us an email to info@kirkmiller.co.uk at any time or by writing to us at our registered office address above.
17. Please be advised that we do not reveal information about identifiable individuals to our advertisers but we may, on occasion, provide them with aggregate statistical information about our site visitors.
18. In addition to the specific disclosures of personal information set out in this Section, we may disclose your personal information 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 information 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.
Controlling the use of your data
19. If you have given us consent to use your data for a particular purpose you can revoke or vary that consent at any time. If you do not want us to use your data or want to vary the consent that you have provided you can email us at info@kirkmiller.co.uk or by writing to us at our registered office address above at any time.
Where we store and transfer your data
20. As part of the Services offered to you, the information you provide to us may be transferred to and stored in countries outside of the European Economic Area (EEA) as we use remote server hosts to provide some aspects of our Service, which may be based outside of the EEA, or use servers based outside of the EEA – this is generally the nature of data stored in “the Cloud”. It may also be processed by staff operating outside the EEA who work for one of our suppliers, e.g. our coaching app, or work for us when temporarily outside of the EEA.
21. A transfer of your personal data may happen if any of our servers are located in a country outside of the EEA or one of our service providers is located in a country outside of the EEA. If we transfer or store your personal data outside the EEA in this way, we will take steps with the aim of ensuring that your privacy rights continue to be protected, as outlined in this privacy policy and in accordance with the DPA and GDPR. If you use our Services while you are outside the EEA, your personal data may be transferred outside the EEA in order to provide you with these services.
22. We do not use or disclose sensitive personal data, such as race, religion, or political affiliations, without your explicit consent.
23. We may disclose your personal data outside of our group: (a) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and (b) if Kirk Miller Online Training Limited’s business is bought by a third-party, in which case personal data held by it about its customers will be one of the assets to transfer to the buyer. However, any such transfer will only be on terms that the confidentiality of your personal data is protected and that the terms of this privacy policy will continue to be complied with by the recipient.
24. Otherwise, we will process, disclose or share your personal data only if required to do so by law or in the good faith belief that such action is necessary to comply with legal requirements or legal process served on us or the website.
25. You have the right to opt out of our processing your personal data for marketing purposes by contacting us on email at info@kirkmiller.co.uk or by writing to us at our registered office address above.
Security
26. The transmission of information via the Internet or email or instant messaging is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data while you are transmitting it to our site, by email, or instant messaging; any such transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
27. Where we have given you (or where you have chosen) a password so that you can access certain service related software or parts of our site, you are responsible for keeping this password confidential. You should choose a password it is not easy for someone to guess.
Retaining and Deleting Your Personal Information
28. We will retain your personal information as follows:
– For as long as we have a continued legitimate business need to do so, such as managing our relationship with you and managing our operations;
– For as long as someone could bring a claim against us; and/or where such retention is necessary for compliance with a legal obligation to which we are subject
– Retention periods in line with legal and regulatory requirements or guidance.
Our Sites
Third-party links
29. You might find links to third-party websites on our sites. These websites should have their own privacy policies, which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.
Use of cookies
30. Our Website uses cookies. We use cookies to gather information about your computer for our services and to provide statistical information regarding the use of our Website. Such information will not identify you personally – it is statistical data about our visitors and their use of our Website. This statistical data does not identify any personal details whatsoever. We may also gather information about your general Internet use by using a cookie file. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer, as cookies contain information that is transferred to your computer’s hard drive. They help us to improve our Website and the Service that we provide to you. All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular parts of our Website. Where we work with advertisers on our Website, our advertisers may also use cookies, over which we have no control. Such cookies (if used) would be downloaded once you click on advertisements on our Website.
Your rights
31. The DPA and GDPR give you the right to access information held about you by us. Please write to us or contact us by email if you wish to request confirmation of what personal information we hold relating to you. You can write to us by email to info@kirkmiller.co.uk. There is no charge for requesting that we provide you with details of the personal data that we hold. We will provide this information within one month of your requesting the data.
32. You have the right to change the permissions that you have given us in relation to how we may use your data. You also have the right to request that we cease using your data or that we delete all personal data records that we hold relating to you. You can exercise these rights at any time by writing to us by email to info@kirkmiller.co.uk or by writing to us at our registered office address above.
Changes to this policy
33. We may update these policies to reflect changes to the website and customer feedback. Please regularly review these policies to be informed of how we are protecting your personal data.
34. We welcome any queries, comments or requests you may have regarding this Privacy Policy. Email us at info@kirkmiller.co.uk or write to us at our registered office address (clause 2)
LAST MODIFIED
This policy is effective July 12, 2021.