Privacy Policy

 

Introduction

 

Here you can find information on how I collect and process personal data through the use of my website www.thehughosborne.com, including information you give through the site when you purchase a product or register for my mailing list, free resources, and occasional emails.

By providing your data, you warrant to me that you are over 13 years of age.

Hugh Osborne is the data controller at www.thehughosborne.com and is responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details for Hugh Osborne are as follows

Full name of legal entity: Hugh Osborne Coach & Hypnotherapist

Registered Address: Duffourstrasse 106 8008 Zürich, Switzerland.

If you are not happy with any aspect of how I collect and use your data please contact me so I can try and resolve it for you. The Swiss Federal Data and Information Commissioners Website is here.

 

Data that I Hold

 

I hold and use data in order to provide support and advice via the services that I offer. Personal data means any information capable of identifying you as an individual. It does not include anonymous data. I may process certain types of personal data in the following ways:

  • Identity Data, which may include your first name, maiden name, last name, marital status, title, date of birth and gender.
  • Contact Data, which may include your home address, delivery address, email address and telephone numbers.
  • Marketing and Communications, which may include preferences in receiving marketing communications from me.
  • Transaction Data, which may include details about financial payments made by my customers & clients.
  • Technical Data, which may include IP (Internet Protocol) addresses, Browser Type and Version, Browser Plug-in Types and versions, Time Zone Setting and Location, Operating System and Platform and Other Technology on the devices you use to access thehughosborne.com.
  • Usage Data, which may include information about how people use my website, products and services.
  • Aggregated Data – I may also process aggregated data but this does not reveal people’s identity and therefore is not considered personal data. An example would be reviewing a website visitors usage to work out the percentage usage of a specific feature of thehughosborne.com.

 

How I Collect Data

 

I collect data about you via a number of ways:

  • Direct interactions: In which you may provide data by completing the contact form or subscribe forms on thehughosborne.com
  • Automated technologies or interactions: As you use thehughosborne.com, I may automatically collect Technical Data about your equipment, browsing actions and usage patterns. I collect this data by using Cookies, Server Logs and similar technologies. Please see my Cookie Policy for further details.
  • Third party or publicly available sources: I may receive personal data about you from various third parties and public sources:
  • Website analytics providers such as Google based outside of Switzerland and EU legislation.
  • Internet search providers based outside of Switzerland and EU legislation.
  • Contact, Financial and Transaction Data from providers of payment and delivery services such as Paypal based outside the EU.

 

I will only use your personal data where legally permitted. The most common uses of your personal data are as follows:

  • I need to perform a contract between myself, and a client.
  • Where it is necessary for mine, and a client’s legitimate interests (or those of a third party) and the client’s interests and fundamental rights do not override those interests.
  • Where I need to comply with obligations set by regulators or the law.

 

Uses of Data

 

Below is a description of the ways I may use personal data and the legal grounds on which I will process such data.

I may process your personal data for more than one lawful ground, depending on the specific purpose for which I am using your data.

 

Delivery of Services

 

  • To process and deliver my services including managing payments for the purpose of contract.
  • To manage my relationship with you. This may include notifying you about changes to my terms or privacy policy or asking you to leave a review of my services, to comply with legal obligations, or for legitimate interests to keep my records updated and to study how customers use my products/services.
  • To administer and protect my business and website including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, for the purpose of legitimate interests for running my business, provision of administration and IT services, network security, to prevent fraud and to comply with a legal and regulatory obligation.
  • To facilitate the delivery relevant and useful content to you.
  • To use data analysis to improve my website, products/services, marketing, customer relations and experiences (technical; usage) for the purpose of legitimate interests to define types of customers for my products and services, to keep my site updated and relevant, to develop my business and to inform my marketing strategy.
  • To make suggestions and recommendations to you about goods or services that may be of interest to you (identity; contact; technical; usage; profile) for the purpose of legitimate interests to develop my products/services and grow my business.

 

Marketing Communications

 

You may receive marketing communications from me if you have:

  • Purchased goods or services from me; or provided me with your details when you registered for free resources; and in each case, you have not opted out of receiving that marketing. You can ask me to stop sending you marketing messages at any time by using the unsubscribe links on any marketing message sent to you or replying to any email I send. Where you opt out of receiving my marketing communications, this will not apply to personal data provided to me as a result of a providing a service to you as a client/customer.

 

Change of Purpose

 

I will only use personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose.

If I need to use personal data for a purpose unrelated to the purpose for which I collected the data, I will notify you and will explain the legal ground of processing.

I may process your personal data without your knowledge or consent where this is required or permitted by regulations or law.

 

Disclosures of Personal Data

 

I may have to share personal data with the parties set out below for the purposes set out in how I use your personal data:

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, accountants and insurers who provide services to me.
  • The Zürich Steueramt (Tax Department), regulators and other authorities based in Switzerland and other relevant jurisdictions who require reporting of processing activities in certain circumstances. I require all third parties to whom I transfer your data to respect the security of your personal data and to treat it in accordance with the law. I only allow such third parties to process your personal data for specified purposes and in accordance with my instructions.

 

International Transfers

 

Some of my third parties service providers are based outside of Switzerland the European Economic Area so their processing of personal data will involve a transfer of data outside the EEA.

Whenever I transfer personal data out of the EEA, I do my best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

  • I will only transfer personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • If I use certain service providers, I may use specific contracts or codes of conduct or certification mechanisms approved by Switzerland and The European Commission, which give personal data the same protection it has in across The Swiss and EU territories.
  • Where I use providers based in the United States, I may transfer data to them if they are part of the EU-US Privacy Shield, which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards are available, I may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time

 

Data Security

 

I 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, I limit access to personal data to those employees; agents, contractors and other third parties who have a business need to know such data. They will only process personal data on my instructions and they are subject to a duty of confidentiality.

I 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 I am legally required to do so.

I will only retain personal data for as long as necessary to fulfill the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask me to delete your data: see below for further information.

In some circumstances I may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case I may use this information indefinitely without further notice to you.

 

Your Legal Rights

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

 

If you wish to exercise any of the rights set out above, please contact me.

There is no charge to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances.

I may need to request specific information from you to help confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask for further information in relation to your request to speed up our response.

I will do my best to respond to all legitimate requests within one month.

 

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. I do not control these third-party websites and are not responsible for their privacy statements. When you leave my website, I encourage you to read the privacy notice of every website you visit.

 

Website 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. To read the Cookie Policy for this website please click here.

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