The Coaching Manual Limited a company registered in England with company number 07567271 whose registered office is at Altspace, F1, Kennedy House, 31 Stamford St, Altrincham, WA14 1ES ("we", "us" and "our") takes the privacy rights of users of the TOPTEKKERS.COM platform, applications and website ("Site") seriously. We are the data controller and we will process your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 and national laws which relate to the processing of personal data (“Data Protection Legislation”).
If you are one of our suppliers or a non-registered user please see sections 5 and 7 of this policy that provide specific details regarding how we process your personal data.
2. Your data
3. How we collect your data
We may collect and process Your Data in the following circumstances: Whenever you visit TOPTEKKERS.CLUB. We may collect details of your visits including, but not limited to, traffic data, location data, and other communication data and the resources you access (see section 3.2.2 below).
When you register to use TOPTEKKERS.CLUB.
Whenever you or a third party provide Your Data on an online form on TOPTEKKERS.CLUB (for example, when you create progress reports, teams and other material via mobile applications, when you enter competitions or free prize draws, etc).
Whenever you provide Your Data to us when reporting a problem with TOPTEKKERS.CLUB, making a complaint, making an enquiry or contacting us for any other reason.
Whenever you complete one of our voluntary surveys that we use for research purposes.
Whenever you disclose Your Data to us, or we collect Your Data from you, in any other way, through TOPTEKKERS.CLUB or otherwise.
IP Address - We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection. We may also collect information about your device’s operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
4. How we use your information
We use Your Data for our own legitimate interests, in order to:
Monitor, develop and improve TOPTEKKERS.CLUB and your experience and ensure the content of TOPTEKKERS.CLUB is presented in the most effective manner for you and for your computer or device.
Process your registration to use TOPTEKKERS.CLUB and provide you with a user name and password.
Provide you with information, products or services that you request from us.
Ensure the security of your account.
Allow you to participate in interactive features of our service, should you choose to do so.
Notify you about changes to our service.
Process and deal with any complaints or enquiries made by you.
Investigate any suspected breach of the terms of service by or otherwise relating to you.
Contact you for marketing purposes.
5. Non-registered user data
Where you do not have an account with us and your personal data is uploaded to a team or club by a third party we will not share your personal data. We do not share or syndicate personal data relating to children under the age of 14. You have the right to object to us using Your Data in this way at any time by contacting us using the details in section 18 of this policy in addition to your other rights set out in section 15.
6. Retention of your data
Where you are a registered user of the Site, subject to exercising your rights detailed in section 15 of this policy, we retain Your Data for as long as you remain an active user of your account. Where there has not been any activity on your account for three years we will contact you to check you still wish to retain your account with us. Where you decide to cancel your account or we do not hear further from you, your account will be de-activated and Your Data will be deleted. Where you have subscribed to receive marketing correspondence from us we will keep your personal data for marketing purposes whilst your account remains active and for the period of time referred to above. This is subject to exercising your right to unsubscribe from receiving such correspondence at any time.
Where you are a non-registered user or a registered user whose personal data has been uploaded to a team or club, we will store Your Data on our software for the benefit of your club for as long as your Club requires (we do not use this information for our own purposes). For details of how long Your Data is retained by your club, please contact your club direct.
7. Supplier data
We will collect details such as a contact name, email address, telephone number, and bank details in order to contact you about goods and/or services we have ordered from you, to place further orders and to pay you for the goods or services supplied. We may share your data with our employees to manage our relationship with you and we will keep the personal data for as long as we require your goods and services and for a period of 6 years further to being provided with the goods/services. You may exercise any of the rights referred to in section 15 of this policy in relation to your personal data.
8. If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide the data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
In addition to the uses described in sections 2 to 7 above, we may also use Your Data for our legitimate interests including for marketing, market research and related purposes, such as
Providing you with information about our products and services, or related products and services via email/post/telephone/text which may be of interest to you.
Asking you to participate in market research, for example, surveys about topical issues, our services, and products. We will always try to tell you before you participate in a survey on how any information you provide in the survey will be used.
Email us at email@example.com you have subscribed to receive marketing correspondence from us we will keep personal data for the period set out in section 6.1 of this policy.
We do not share customer data with third parties. All customer data collected by TopTekkers is for the promotion and development of TopTekkers only.
10. Disclosure of your data to Third Parties
In addition to the third parties mentioned above, we may disclose Your Data to third parties for our legitimate interests as follows:
To our employees and agents to administer your online account.
To payment providers to process online payments for our goods and/or services;10.1.3IT software providers that host our website, store data and provide other software services on our behalf.
To reputable third parties in order to gather general statistical information about the Website user base, sales patterns, traffic volumes, and related matters but these details will not include information personally identifying you.
HM Revenue and Customs, regulators and other authorities who require reports of processing activities in certain circumstances.
To the police, regulatory bodies or legal advisers in connection with any alleged criminal offence or suspected breach of the Terms of Service or where We are under a duty to disclose or share Your Data in order to comply with any legal obligation.
11. Cross border data transfers
On 16th July 2020, the CJEU, which is Europe’s highest court, invalidated the EU-US Privacy Shield, meaning that organisations who were transferring data to the USA under the Privacy Shield, no longer had protection in place for customers. The Coaching Manual will continue to adhere to the Privacy Shield principles and will continue to protect EEA, UK and Swiss Data under these principles to which it has self-certified compliance.
In addition to this, The Coaching Manual commits to transfer and process all of its users’ EU and UK data in compliance with Standard Contractual Clauses, which remain a valid data export mechanism which automatically apply in accordance with updates to The Coaching Manual’s data protection policies.
Why do we transfer UK and EU data? The Coaching Manual works with USA based Software providers to help us deliver The Coaching Manual service in an effective way. We do not sell data or transfer data for any commercial purposes.
11.4 Who processes customer data in the USA?
11.4.1 Google Cloud Services
Our customers database is securely hosted on Google Cloud Services. With built in encryption at rest, Google Cloud is one of the safest data hosting services there is. You can find more information about Google Cloud Services here
We use Mailchimp as our marketing email provider. This allows The Coaching Manual to help users get set up with The Coaching Manual as well as allow us to inform users about new features and content from time to time. You can find out about Mailchimp’s compliance with EU Data Transfers here
Sengrid/Twilio is used by The Coaching Manual to provide transactional emails to customers. This allows us to verify that email addresses are correct and it also allows users to reset passwords, should they find themselves locked out of their account. You can see more on Sendgrid/Twilio’s data protection rule here
12. Data security
Where we have given You (or where You have chosen) a password which enables you to access certain parts of THECOACHINGMANUAL.COM, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet and mobile networks is not completely secure. Although we will do our best to protect Your Data, we cannot guarantee the security of Your Data transmitted to TOPTEKKERS.CLUB. Any transmission is at your own risk. Once we have received Your Data, we will use strict procedures and security features to try to prevent unauthorised access.
Information you provide to us is stored on our secure servers. We have implemented appropriate physical, technical and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access.
13. Links to other websites
TOPTEKKERS.CLUB may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these when you leave our Site, we encourage you to read the privacy notice/policy of every website you visit.
14. Legal basis for processing your personal data
We will only use your personal data where the law allows us to. Most commonly, we will use your personal data in the following circumstances:
For the performance of a contract we enter into with you.
Where necessary for compliance with a legal or regulatory obligation we are subject to.
For our legitimate interests (as described within this policy) where your interests and fundamental rights do not override these interests.
15. Access to, updating, deleting and restricting the use of your data
It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes. Where you are a registered user of TOPTEKKERS.CLUB you may update your data contained in your online account at any time).
Data protection legislation gives you the right to object to the processing of your personal data in certain circumstances or withdraw your consent to the processing of your personal data where this has been provided. You also have the right to access information held about you and for this to be provided in an intelligible form. If you would like a copy of some or all of your personal data, please send an email to firstname.lastname@example.org. In certain circumstances, we reserve the right to charge a reasonable fee to comply with your request.
You can also ask us to undertake the following:
Update or amend Your Data if you feel this is inaccurate.
Remove Your Data from Our database entirely.
Send you copies of Your Data in a commonly used format and transfer Your Data to another entity where you have supplied this to us, and we process this electronically with your consent or where necessary for the performance of a contract.
Restrict the use of Your Data.
We may request specific information from you to help us confirm your identity and your right to access/provide you with the personal data we hold about you or make your requested changes. Data protection legislation may allow or require us to refuse to provide you with access to some or all of Your Data/comply with requests made in accordance with your rights referred to above. If we cannot provide you with access to Your Data, or deal with any other request we receive, we will inform you of the reasons why subject to any legal or regulatory restrictions.
Please send any requests relating to the above to our Data Protection Lead at email@example.com specifying your name and the action you would like us to undertake. Where you are a registered user please use the email address you used to register with us and your username. Note that in relation to requests to access Your Data, we reserve the right in certain circumstances to charge a reasonable fee to carry out your request.
16. Right to withdraw consent
Where you have provided your consent to the collection, processing, and transfer of your personal data, you may withdraw that consent at any time. This will not affect the lawfulness of data processing based on consent before it is withdrawn. To withdraw your consent please contact us at firstname.lastname@example.org
18. Contact us
If You have any questions, comments or requests regarding this policy or how We use Your Data please contact our Data Protection Lead at email@example.com. This is in addition to your right to contact the Information Commissioners Office if you are unsatisfied with our response to any issues you raise at https://ico.org.uk/global/contact-us/.