Introduction
What we do (and don’t do!) with the information you give us.
Numero P takes data privacy seriously. This privacy notice
explains who we are, how we collect, share and use Personal Information, and
how you can exercise your privacy rights. As a company processing personal
data, we are regulated by the General Data Protection Regulation (GDPR).
If you have any questions or concerns about our use of your
Personal Information, then please contact us using the contact details provided
on the contact page.
If we provide you with notice of different or additional privacy
notices, those notices will govern such interactions.
1. The Basics
A. About Us
Numero P is a Coach Consultancy. We offer; Executive, Business and
Brand + Creative Coaching to our clients worldwide. Our registered office is
based in Gibraltar.
We are members of Mailchimp and use their platform and tools for
our website tracking, email marketing campaigns and other online marketing
activity.
Our care of Client and Visitor data is supported by Mailchimp
privacy policies and cookie statement.
B. Key Terms
In this privacy notice, these terms have the following meanings:
“A!iliate” an entity that directly or indirectly Controls, is
Controlled by or is under common Control with an entity.
“Distribution List” a list of Contacts we may upload to
Mailchimp to manage our email marketing campaigns and all associated
information related to those Contacts (for example, email addresses).
“Personal Information” any information that identifies
or can be used to identify an individual directly or indirectly. Examples of
Personal Information include, but are not limited to, first and last name, date
of birth, email address, gender, occupation, or other demographic information.
“Client” any person or entity that has registered
interest in our services.
“Visitor” depending on the context, any person who
visits any of our Numero P Sites, offices, or otherwise engages with us at our
events or in connection with our marketing or recruitment activities.
“you” and “your” depending on the context,
either a Client, or a Visitor.
2. Privacy for clients
This section applies to the Personal Information we collect and
process from a Client when they register interest in our services. If you are
not a Client, the Visitors section of this policy may be more applicable to you
and your data. In this section, “you” and “your” refer to
Clients.
A. Information We Collect
The Personal Information that we collect depends on the context of
your interactions with Numero P, the services we are providing, your location,
and applicable law. However, the Personal Information we collect broadly falls
into the following categories:
(i) Information you provide to us: You (or your organisation) may
provide certain Personal Information when you register interest in our
services. For example, when you visit our website or communicate with us in any
other way.
This information may include:
Business contact information (such as your name, job title,
organisation, location, phone number and email address)
Marketing information (such as your contact preferences)
Payment information (including your credit card numbers and
associated identifiers and billing address)
(ii) Information we collect automatically: When you visit our website,
we may automatically collect or receive certain information about your device
and usage of our website (collectively “Service Usage Data”). In some (but not
all) countries, including countries in the European Economic Area (“EEA”), this
information is considered Personal Information under applicable data protection
laws. We use Mailchimp cookies and other tracking technologies to collect some
of this information. For further information, please review MailChimp’ Cookie
Statement available here.
Service Usage Data may include:
Device information: We may collect information about the device
and applications you use to access our Website, such as your IP address, your
operating system, browser ID, and other system and connection information
Log data: We don’t log any of this data ourselves, Mailchimp
provide all our tracking information. Mailchimp web servers keep log files that
record data each time a device accesses those servers and the nature of each
access, including originating IP addresses and activity (such as the date/time
stamps associated with usage, pages and files viewed, searches and other
actions you take, device event information (such as system activity, error
reports (sometimes called ‘crash dumps’)), and hardware settings. We may also access
metadata and other information associated if you were to upload a file through
our website
Usage data: We collect usage data about you whenever you interact
with our website, which may include the dates and times you access the website
and your browsing activities (such as what pages of the website you used). We
also collect information regarding the performance of our marketing activity,
including metrics related to the deliverability of emails and other
communications we send through the Mailchimp Service
(iii) Information we collect from other sources: We may obtain
information about you from third-party sources, such as public databases,
social media platforms, third-party data providers, and our joint marketing
partners.
Examples of the information we receive from other sources include
demographic information (such as age and gender), device information (such as
IP addresses), location (such as city and country), and online behavioral data
(such as information about your use of social media websites, page view
information, search results and links). We use this information, alone or in
combination with other Personal Information we collect, to enhance our ability
to provide relevant marketing and content to you and tailor our services and
products to be more relevant.
B. Use of Personal Information
We may use the Personal Information we collect or receive (alone
or in combination with other data we source) for the purposes and on the legal
bases identified below:
To provide, support and improve our Service offering to perform
our contract with you. For example, this may include sharing your information
with third parties in order to provide additional external assessments to
support our Service. When we share your Personal Information with third parties,
we take steps to protect your information in a manner that is consistent with
our obligations under applicable privacy laws.
To bill and collect money owed to us by you for receiving our
services or where we have not entered into a contract with you, in accordance
with our legitimate interests to operate and administer our Service. This
includes sending you emails, invoices and receipts. We use third parties for
secure credit card transaction processing, and those third parties collect
billing information to process your orders and credit card payments.
To perform data analytics projects in reliance on our legitimate
business interests in improving and enhancing our services and products for our
Clients. Our data analytics projects may use data from Personal Information we
have collected from Clients to improve our service offering. We use information
like your open rates, service history, so we can make more informed marketing
decisions that will benefit our Clients. For example, we may use data to assist
audience segmentation planning. If you would not like to have your data used
for this purpose, you can opt out of data analytics projects by emailing us at
keri@numerop.com.
To personalise the Service, content and advertisements we serve to
you in reliance on our legitimate interests in supporting our marketing
activities. We may use your Personal Information to serve you specifically,
such as to deliver marketing information, product recommendations and
non-transactional communications (e.g. email, telemarketing calls, SMS, or push
notifications) about us, in accordance with your marketing preferences.
C. Third-Party Integrations
We may use the Personal Information we collect or receive through
integrations and plugins with our website. For example, Google integration;
Google Sheets, Google Contacts, Google Analytics and Google Drive. This is used
to improve our service offering and website design to provide a better customer
experience.
D. Cookies and Tracking Technologies
We and our third-party partners may use various technologies to
collect and store Service Usage Data when you visit our website (as discussed
above), and this may include using cookies and similar tracking technologies,
such as pixels, and web beacons. For example, Mailchimp use web beacons in the
emails we send, which enables them to track (on our behalf) certain behaviour,
such as whether the email sent was delivered and opened and whether links
within the email were clicked on. Web beacons allow them to collect information
such as the recipient’s IP address, browser, email client type and other
similar data as further described above. We use this information to measure the
performance of our email campaigns, to provide analytics information, enhance
the effectiveness of our Service offering, and for other purposes described
above.
Use of cookies and other tracking technologies – see Cookie Statement.
E. Distribution Lists
In order to send an email campaign, we have to upload a
Distribution List to Mailchimp that provides information about our Clients,
such as names and email addresses. They use and process this information to
provide the Service in accordance with our contract and this privacy notice.
If a Client chooses to Forward that email to a Friend (FTF), we do
not store their friend’s email address, and no one is added to any Distribution
List as a result of the FTF link. We only see an aggregate number of times our
email campaign was forwarded by a Client; we do not have access to the email
addresses who receive forwarded content.
F. Your Data Protection Rights
Depending on the country in which you reside, you may have the
following data protection rights:
To access; correct; update; port; delete; restrict; or object to
our processing of your Personal Information
You can manage your individual preferences by contacting us
directly on email at keri@numerop.com
The right to complain to a data protection authority about the
collection and use of Personal Information. For more information, please
contact your local data protection authority
Similarly, if Personal Information is collected or processed on
the basis of consent, the data subject can withdraw their consent at any time.
Withdrawing your consent will not affect the lawfulness of any processing we
conducted prior to your withdrawal, nor will it affect the processing of your
Personal Information conducted in reliance on lawful processing grounds other
than consent.
We respond to all requests we receive from individuals wishing to
exercise their data protection rights in accordance with applicable data
protection law. We may ask you to verify your identity in order to help us
respond efficiently to your request.
3. Privacy for visitors
This section applies to Personal Information that we collect and
process when you visit the Numero P Sites, and in the usual course of our
business, such as in connection with our recruitment, events, sales and
marketing activities or when you visit our offices. In this section,
“you” and “your” refer to Visitors.
A. Information We Collect
(i) Information you provide to us on the Numero P website or
otherwise: Our Sites offer various ways to contact us, such as through form
submissions, email or phone, to inquire about our company and Services. For
example, we may ask you to provide certain Personal Information when you
express an interest in obtaining information about us, our Services or
products, take part in surveys, subscribe to marketing, apply for a role with
Numero P, or otherwise contact us. We may also collect Personal Information from
you in person when you attend our events or trade shows, if you visit our
offices (where you will be required to register as a visitor and provide us
with certain information that may also be shared with our service providers) or
via a phone call with one of our team to provide additional information when
you communicate with us or otherwise interact with us, and we may keep copies
of any such communications for our records.
The Personal Information we collect may include:
Business contact information (such as your name, phone number,
email address and country)
Professional information (such as your job title, institution or
company)
Nature of your communication
Marketing information (such as your contact preferences)
Any information you choose to provide to us when completing any
‘free text’ boxes in our forms
(ii) Information we collect automatically: When you visit our
website, we may automatically collect or receive certain information about your
device and usage of our website (collectively “Service Usage Data”). In some
(but not all) countries, including countries in the European Economic Area
(“EEA”), this information is considered Personal Information under applicable
data protection laws. We use Mailchimp cookies and other tracking technologies to
collect some of this information. For further information, please review the
MailChimp Cookie Statement.
The information we collect automatically includes:
Device information: such as your IP address, your browser, device
information, unique device identifiers, mobile network information, request
information (speed, frequency, the site from which you linked to us (“referring
page”), the name of the website you choose to visit immediately after ours
(called “exit page”), information about other websites you have recently
visited and the web browser you used (software used to browse the internet)
including its type and language)
Usage data: such as information about how you interact with our
emails, website, and other websites (such as the pages and files viewed,
searches, operating system and system configuration information and date/time
stamps associated with your usage)
B. Use of Personal Information
We may use the information we collect through our website and in
connection with our events and marketing activities (alone or in combination
with other data we collect) for a range of reasons in reliance on our
legitimate interests, including:
To provide, operate, optimise, and maintain the Numero P website
To send you marketing information, product recommendations and
non- transactional communications (e.g. email, telemarketing calls, SMS, or
push notifications) about us, in accordance with your marketing preferences,
including information about our products, services, promotions or events as
necessary for our legitimate interest in conducting direct marketing or to the
extent you have provided your prior consent
For recruitment purposes if you have applied for a role with
Numero P
To respond to your online inquiries and requests, and to provide
you with information and access to our services that you have requested from us
To manage the Numero P website and system administration and
security
To manage event registrations and attendance, including sending
related communications to you
To register visitors to our offices for security reasons and to
manage non- disclosure agreements that visitors may be required to sign
To improve the navigation and content of the Numero P website
To identify any server problems or other IT or network issues
To process transactions and to set up online accounts
To compile aggregated statistics about site usage and to better
understand the preferences of our Visitors
To help us provide, improve and personalize our marketing
activities
To facilitate the security and continued proper functioning of the
Numero P website
To carry out research and development to improve our Numero P
website, services and products
To conduct marketing research, advertise to you, provide
personalised information about us on and off our Numero P website, and to
provide other personalised content based on your activities and interests to
the extent necessary for our legitimate interests in supporting our marketing
activities or advertising our Service or instances where we seek your consent
To cooperate with public and government authorities, courts or
regulators in accordance with our legal obligations under applicable laws to
the extent this requires the processing or disclosure of Personal Information
to protect our rights or is necessary for our legitimate interest in protecting
against misuse or abuse of our Numero P website and Service, protecting
personal property or safety, pursuing remedies available to us and limiting our
damages, complying with judicial proceedings, court orders or legal processes,
or responding to lawful requests
C. Public Information and Third-Party Websites
Blog. We may have public blogs on the Numero P website. Any
information you include in a comment on our blog may be read, collected, and
used by anyone. If your Personal Information appears on our blogs and you want
it removed, contact us at keri@numerop.com. If we are unable to remove your
information, we will tell you why.
Social media platforms and widgets. The Numero P website may
include social media features, such as Like buttons. These features may collect
information about your IP address and which page you are visiting on our
website, and they may set a cookie to make sure the feature functions properly.
Social media features and widgets are either hosted by a third party or hosted
directly on our Numero P website. We also maintain presences on social media
platforms, including Facebook, Linkedin, Twitter, and Instagram. Any
information, communications, or materials you submit to us via a social media
platform is done at your own risk without any expectation of privacy. We cannot
control the actions of other users on these platforms or the actions of the
platforms themselves. Your interactions with those features and platforms are
governed by the privacy policies of the companies that provide them.
Links to third-party websites. The Numero P website may include
links to other websites, whose privacy policies may be different from ours. If
you submit Personal Information to any of those sites, your information is governed
by their privacy notices. We encourage you to carefully read the privacy notice
of any website you visit.
Contests and sweepstakes. We may, from time to time, offer
surveys, contests, sweepstakes, or other promotions on the Numero P website or
through social media (collectively, “Promotions”). Participation in
our Promotions is completely voluntary. Information requested for entry may
include Personal Information such as your name, address, date of birth, phone
number, email address, username, and similar details. We use the information
you provide to administer our Promotions. We may also, unless prohibited by the
Promotion’s rules or law, use the information provided to communicate with you,
or other people you select, about our Services. We may share this information
with our affiliates and other organizations or service providers in line with
this privacy notice and the rules posted for our Promotions.
D. Cookies and Tracking Technologies
We use cookies and similar tracking technologies through Mailchimp
to collect and use Personal Information about you, including to serve
interest-based advertising. For further information about the types of cookies
and tracking technologies Mailchimp use see their Cookie Statement.
E. Other Data Protection Rights
Depending on the country in which you reside, you may have the
following data protection rights:
To access; correct; update; port; delete; restrict or object to
our processing of your Personal Information. You can exercise these rights by
emailing keri@numerop.com
You may also have the right to complain to a data protection
authority about our collection and use of your Personal Information. For more
information, please contact your local data protection authority.
Similarly, if we have collected and processed your Personal
Information with your consent, then you can withdraw your consent at any time.
Withdrawing your consent will not affect the lawfulness of any processing we
conducted prior to your withdrawal, nor will it affect the processing of your Personal
Information conducted in reliance on lawful processing grounds other than
consent. You can also contact us at any time to update your marketing
preferences.
We respond to all requests we receive from individuals wishing to
exercise their data protection rights in accordance with applicable data
protection laws. We may ask you to verify your identity to help us efficiently
respond.
5. General information
A. How We Share Information
Advertising partners: We may partner with third-party advertising
networks, exchanges, and social media platforms (like Facebook) to display
advertising and we may share Personal Information of Clients and Visitors with
them for this purpose. We and our third-party partners may use cookies and
other similar tracking technologies, such as pixels and web beacons, to gather
information about your activities on the Numero P website and other sites in
order to provide you with targeted advertising based on your browsing
activities and interests. For more information please contact us at
keri@numerop.com
B. Your Choices and Opt-Outs
Clients and Visitors who have opted in to our marketing emails can
opt out at any time by clicking the “unsubscribe” link at the bottom
of our marketing messages.
Also, all opt-out requests can be made by emailing us at
keri@numerop.com. Please note that some communications (such as service
messages, account notifications, billing information) are considered
transactional and necessary for account management, and Clients cannot opt out
of these messages unless you terminate our contract.
C. Retention of Data
We retain Personal Information where we have an ongoing legitimate
business or legal need to do so. Our retention periods will vary depending on
the type of data involved, but, generally, we’ll refer to these criteria in
order to determine retention period:
Whether we have a legal or contractual need to retain the data.
Whether the data is necessary to provide our Service
Whether our Clients would reasonably expect that we would retain
the data until they terminate our contract
When we have no ongoing legitimate business need to process your
Personal Information, we will either delete or anonymise it or, if
this is not possible (for example, because your Personal Information has been
stored in backup archives), then we will securely store your Personal
Information and isolate it from any further processing until deletion is
possible
D. Questions and Concerns
If you have any questions or comments, or if you have a concern
about the way in which we have handled any privacy matter, please contact us by
postal mail or email at keri@numerop.com
Last Updated: November 2020