Data Protection
& Privacy Notice

Your privacy and the protection of your data is very important to us.

We aim to be GDPR compliant.

YOUR CONFIDENTIALITY IS ASSURED

Your confidentiality is assured when participating in any Gutsy events or services. We request confidentiality from all participants so that everyone can feel safe and that whatever they share will not be repeated or discussed by other people outside the group.

Success stories and case studies will be shared through marketing materials only with the featured individual’s written permission.

Any testimonials you provide to us will be shared without further permission.

1. WHO WE ARE

This privacy notice provides you with details of how we collect and process your personal data through your use of our site.

Our website address is: https://www.sogutsy.co.

For purposes of the applicable Data Protection Laws, Susannah Worth is the “data controller”. This means that Susannah Worth (referred to here as “we”, “us” or “our”) determines the purposes for which, and the manner in which, your data is processed and is responsible for your personal data.

2.  WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND WHY

Personal data means any information capable of identifying you as an individual. It does not include anonymised data. When we speak about “processing” this means the activity of reading and responding to any information you provide us with in order to support you through Gutsy events and services.

This includes:

Communication Data

This is any communication that you send to us whether by email, SMS, social media messaging, social media messaging or any other communication. We process this data for the purposes of communicating with you, for record-keeping and for advising you. Our lawful ground for this processing is our legitimate interests which, in this case, are to reply to communications sent to us, to keep records, to support you in your journey through Gutsy events and services and to establish, pursue or defend any legal claims. (When we speak about “legitimate Interests” this means that the GDPR law permits us to store and process your data as described.)

Customer Data

This is data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your debit/credit card details. We also request when booking onto Gutsy events and services that you inform us of your reasons for attending and any information we need to know to support you better. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us (or in other words delivering the course or session you have booked) and/or taking steps at your request to enter into such a contract.

User Data

This is data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and Gutsy events and services.

Technical Data

This includes data about your use of our website and online services and relates our use of Google Analytics. Google Analytics may track your IP address (to establish your geographical location – this information is not visible to us), details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and Gutsy events and services, and to inform our marketing strategy.

Marketing Data

This includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions and free give-aways, and to deliver relevant website content to you and information about Gutsy events and services. Our lawful ground for this processing is our legitimate interests which in this case is to provide you with the information you have requested, to develop Gutsy events and services and to make them more available to the people who need them.

We may use Customer Data, User Data and Marketing Data to deliver relevant website content and advertisements and to measure or understand the effectiveness of our advertising. Our lawful ground for this processing is legitimate interests which is to grow Gutsy events and services and make them more available to the people who need them. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow Gutsy).

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences. We do not carry out automated decision-making or any type of automated profiling.

3. MARKETING COMMUNICATIONS

Our lawful ground of processing your personal data to send you our newsletters (marketing communications) is either your consent or our legitimate interests (namely, to grow Gutsy).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications if (i) you made a purchase or asked for information from us about Gutsy events and services or (ii) you agreed to receive marketing communications, and in each case, you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

We do not share your personal data with any third party for their own marketing purposes.

You can ask us to stop sending you our newsletters at any time by following the unsubscribe links on any marketing message sent to you or by emailing us at hello@sogutsy.co at any time.

If you opt out of receiving our newsletter, this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, registrations etc.

4.  DISCLOSURES OF YOUR PERSONAL DATA 

We may have to share your personal data with the parties set out below:

When you join a course or workshop, you will have the option to be connected up with other participants for the purposes of mutual support and social contact. Participants are asked not to use this email group for chain letters, marketing or business purposes without the consent of the individuals in the group. You will have the choice to opt out of this if you wish.

Professional advisers, including lawyers, bankers, auditors and insurers.

Government bodies that require us to report processing activities.

7.  DATA SECURITY 

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed without authorisation.

We will notify you and any applicable regulator of a suspected personal data breach if necessary and if we are legally required to.

8.  DATA RETENTION 

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

When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances, we may anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9.  YOUR LEGAL RIGHTS 

Under data protection laws, you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

If you are within the UK, you can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at hello@sogutsy.co.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us 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. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

If you are within the UK and are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

If you are within the EU and are not happy with any aspect of how we collect and use your data, you have the right to complain to the data protection authority of the country in which you are based. We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

10. 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 notice of every website you visit.