Privacy Policy

Privacy Policy

Last Updated: 13 March 2025

1. Introduction

ETL Advisory Limited trading as Outlaws Coaching ("we," "us," or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and protect your information when you visit our website [Insert Website URL] (the "Website") and when you engage with our coaching services.

This policy complies with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the UK General Data Protection Regulation ("UK GDPR"), the California Consumer Privacy Act ("CCPA"), and other relevant international privacy laws, ensuring protection for users worldwide.

2. Data We Collect

We may collect and process the following types of personal data:

• Identity Data: Name, title, and contact details (email address, phone number, postal address).
• Technical Data: IP address, browser type, time zone setting, and device details.
• Usage Data: Information on how you use our website and services.
• Communication Data: Messages, emails, and inquiries submitted to us.
• Payment Data: If you purchase services, billing information is processed securely by third-party payment providers.
• Children’s Data: Our services are not intended for individuals under 16 (or 13 in the US). We do not knowingly collect data from children. If we become aware of such collection, we will delete the data immediately.

3. How We Collect Data

We collect data in the following ways:

• Direct interactions: When you fill out forms, book coaching sessions, or communicate with us.
• Automated technologies: Cookies, analytics tools, and similar tracking technologies.
• Third-party sources: Payment processors and marketing platforms (where applicable).

4. Purpose of Data Processing

We process your data for the following reasons:

• To provide and manage our coaching services.
• To communicate with you regarding bookings, inquiries, and service updates.
• To improve our website, services, and user experience.
• To comply with legal obligations and protect our business interests.
• For marketing purposes (where explicit consent is given).

5. Legal Basis for Processing (GDPR & UK GDPR Compliance)

Under GDPR and UK GDPR, we process personal data based on the following legal grounds:

• Consent: When you provide explicit consent for marketing or other optional data uses.
• Contractual necessity: When data is necessary to fulfill a coaching agreement.
• Legal obligation: When processing is required by law.
• Legitimate interests: When we have a business interest that does not override your rights (e.g., website analytics, service improvement).

6. Data Sharing & International Transfers

We do not sell your personal data. However, we may share your data with:

• Service providers (e.g., hosting, payment processors, analytics tools) that help us operate our business.
• Legal authorities if required by law.

If we transfer your data outside the UK, EU, or EEA, we ensure adequate protection through:

• EU and UK Standard Contractual Clauses.
• Adequacy decisions by the European Commission and UK authorities.
• Other legally recognized safeguards.

7. Data Retention

We retain personal data only as long as necessary for the purposes stated in this policy. We will delete or anonymize data once it is no longer needed, unless retention is required for legal or tax purposes.

8. Automated Decision-Making

We do not use automated decision-making or profiling that produces legal effects concerning you. If this changes, we will update this policy accordingly.

9. Your Rights Under GDPR, UK GDPR, and Other Privacy Laws

You have the following rights regarding your personal data:

• Right to Access: Request a copy of your personal data.
• Right to Rectification: Request corrections to inaccurate data.
• Right to Erasure: Request deletion of your personal data (subject to legal limitations).
• Right to Restriction: Request limited processing of your data.
• Right to Data Portability: Receive your data in a structured format.
• Right to Object: Object to processing based on legitimate interests or direct marketing.
• Right to Withdraw Consent: Withdraw consent at any time where applicable.

To exercise your rights, contact us at fred.spratt@gmail.com. We will respond within the legal timeframe.

10. Additional Rights for US Residents (CCPA Compliance)

If you are a California resident, you have the following additional rights under the CCPA:

• Right to Know: Request details on the personal data we collect and how we use it.
• Right to Delete: Request deletion of your personal data (with some exceptions).
• Right to Opt-Out of Sale: We do not sell personal data, but if we ever do, you will have the right to opt-out.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise these rights, California residents can contact us at fred.spratt@gmail.com with "CCPA Request" in the subject line.

11. Cookies & Tracking Technologies

We use cookies and tracking technologies to enhance website functionality and analyze usage patterns. You can manage cookie preferences via your browser settings.

For more details, see our [Cookie Policy] (if applicable).

12. Third-Party Service Providers

We may work with third-party service providers to facilitate payments, analytics, and communications. These may include Google Analytics: For website traffic analysis (Google’s Privacy Policy). Our website is hosted by a third-party service provider, which may process certain technical data (such as IP addresses and server logs) to ensure the website's functionality and security. Our hosting provider operates servers that may be located outside the European Economic Area (EEA). If you would like further details about our hosting provider or data transfer safeguards, please contact us using the contact form on the website.

13. Data Security & Breach Notification

We implement appropriate security measures to prevent unauthorized access, loss, or misuse of your data. However, no online system is entirely secure, and we encourage users to take necessary precautions.

In the event of a data breach that may impact your rights and freedoms, we will notify the relevant data protection authorities and affected individuals as required by law.

14. Third-Party Links

Our website may contain links to third-party sites. We are not responsible for their privacy policies, and we encourage you to review them before providing any personal data.

15. Changes to This Privacy Policy

We may update this policy from time to time. The latest version will always be available on our website. Significant changes will be communicated via email or a notice on our website.

16. Contact Information

If you have any questions or concerns about this Privacy Policy or your data rights, please contact us:

ETL Advisory Limited trading as Outlaws Coaching
128 City Road, London, Greater London, EC1V 2NX
Email: fred.spratt@gmail.com

If you are based in the UK, you may also contact the UK Information Commissioner's Office (ICO) at https://ico.org.uk for data protection concerns.

For users in the EU, our business is registered in the UK, but we also operate from Spain, ensuring compliance with EU GDPR regulations. You may contact us for GDPR-related concerns at fred.spratt@gmail.com. If you are based in the EU and have unresolved concerns, you have the right to file a complaint with your national data protection authority.

17. Jurisdiction & Governing Law

This Privacy Policy is governed by UK law for UK users, EU law for EU users, and applicable US state laws (including California CCPA) for US users. Disputes will be resolved under the respective legal frameworks.