Next Gen Money Coach – Privacy Statement

At Next Gen Money Coach, the privacy of visitors to our Website and all of our business contacts is of extreme importance to us. We believe in a responsible and pro-active approach when dealing with their personal data.

This policy sets out how and why we collect, store, use and share personal data generally, our dedication to protect it, as well as your rights in relation to your personal data and details of how to contact us and the UK supervisory authority if you have a complaint.

If you have any questions about how we use your personal data, please contact: [email protected].

1. The types of personal data we collect

We may collect and use the following data about or relating to you:

• Your Identity Data including your first name and surname;
• Your Contact Data including your billing address, email address, and telephone numbers;
• Your Transactional Data including data about our business dealings, transactions and interactions with you;
• Your Technical Data including your IP address when you visit or engage with our Website or LinkedIn;
• Usage Data including data about how you use or search our Website and services including any user preferences;
• Marketing and Communications Data including your preferences in receiving marketing (including newsletters) from us, your communication preferences and your language settings;

2. How and why we use personal data

We use personal data about or relating to you that we collect, or that you provide to us, for the following purposes:

• to respond to your queries;
• to set up session bookings with you and fulfil the terms of our engagement with you;
• to manage, deliver and improve our Website;
• to set and operate cookies and similar technologies on our Website;
• to provide you with marketing information related to our services which we believe may be of interest to you or that you have requested (such as newsletters);
• to handle complaints and disputes;
• to comply with the law and to enforce our legal rights; and
• to perform our day-to-day business operations including business development.

3. Lawful basis for processing

We will only process your personal data where we have a lawful basis to do so. The lawful basis will depend on the purposes for which we have collected and use your personal data. In almost every case, the lawful basis will be one of the following:

• Our legitimate business interests Where we have a legitimate interest to use your personal data in relation to the operation of our business. Also, where it is necessary for system administration purposes and for internal operations.
• Performance of an agreement with you (or in order to take steps prior to entering into an agreement with you). For example:  
  
  • where you have provided your data in order to receive details in relation to our services; or
  • where you have provided your payment data in order to receive our services.
• Compliance with the law: Where we are subject to a legal obligation and need to use your personal data in order to comply with that obligation.
• Consent: You have given consent for us to process your personal data for a specific purpose.

4. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a booking of services you have made with us, but we will notify you if this is the case at the time.

5. How we share your personal data with third-parties

We may share your personal data with our suppliers, contractors, business partners, prospective investors and other service providers. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We may disclose your personal data to other third parties in the following cases:

• if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
• in the case of an emergency, in which case we shall share personal data as is necessary and proportionate; or 
• to protect the rights, property or safety of us or our users, or others, and in order to enforce or apply the terms of our contracts with other Customers (this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. Marketing

Where permitted by law or where we have asked for your consent, we may send you marketing materials which we believe may be of interest to you or that you have requested (such as newsletters).

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may receive marketing communications from us if you have requested information from us or engaged with us and you have not opted out of receiving that marketing.

• Third-party marketing. We are committed to protecting and respecting your personal data. We will not sell or rent your personal data to any third parties. We will not share your personal data with third parties for marketing purposes
• Opting out. You can ask us to stop sending you marketing messages at any time by contacting us at any time at [email protected]. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
  
   

7. Cookies

Please see our cookie policy available for download on our cookie pop-up or in our footer.

8. Age of consent

This Website is not intended for individuals under the age of 18. We do not knowingly collect personally identifiable information from individuals under the age of 18 without permission from a parent or guardian. You represent that you are 18 or older, or that you are 18 or older and you have given us your consent to allow any of your minor dependents to use this site.

9. EU/UK Users - Where we store your personal data

The personal data that we collect from you may be transferred to, and stored within, countries outside the UK and EEA. For example, we share your identity and contact data with Mailchimp (the Rocket Science Group LLC) who manages our contacts and messaging. We also upload personal data to our Google Drive account. This data may be transferred and processed in the USA.

Whenever we transfer your information internationally, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal data and to make sure it is treated securely and in accordance with this privacy policy. In these cases, we rely on approved data transfer mechanisms (such as the EU “Standard Contractual Clauses” or UK “International Data Transfer Agreement” or “UK Addendum”) to ensure your data is subject to adequate safeguards in the recipient country. If you are located in the UK or EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal data and privacy rights in these circumstances.

10. Your rights

Next Gen Money Coach takes your privacy very seriously and wants you to be aware of your rights, which apply to EU/UK users, as follows (for California users, please see the section below entitled “California Privacy Rights”:

• you have the right to request (i) confirmation of whether we process your personal data and (ii) access to a copy of the personal data retained;
• you have the right to have inaccurate personal data rectified, or completed if it is incomplete;
• in certain situations, you have the right to have your personal data erased or transmitted directly to another company, where technically feasible;
• where the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time without impact to any data processing activities that have taken place before such withdrawal;
• you have the right not to be subject to any decisions based solely on automated processing, including profiling, which has legal or other similarly significantly effects on you unless we have your consent, it is authorised by law or it is necessary for the performance of an agreement;
• in certain situations, you have the right to restrict or object to our processing of personal data regarding you; and
• the right to lodge complaints before the UK Information Commissioner’s Office and you may do so at https://ico.org.uk/make-a-complaint/. 

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details. 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.

Please send us an email at [email protected] if you would like to exercise any of your rights.

11. Data security

We 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. We take steps to ensure that your data is treated securely and in accordance with this policy. Unfortunately, the transmission of data via the internet is not completely secure. Although we will do our best to protect your personal data, for example, by encryption or by using pseudonymisation in the case of credit card data on payment, we cannot guarantee the security of your data transmitted via the internet; any transmission is at your own risk.

We have appropriate technical and organisational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other individuals. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

In addition, we limit access to your personal data to those employees and other third parties who have a business need to know.

We may, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. 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 policies. Please check these policies before you submit any data to these websites.

12. How long we keep your personal data

We retain your data for as long as it is necessary for the purposes for which it was collected and processed. Additionally, we retain data for the purposes of satisfying any legal, regulatory, accounting, finance, tax, reporting and insurance requirements after which we take steps to destroy or de-identify personal data when the data is no longer required for any purpose for which it may be used or disclosed by us and we are no longer required by law or regulation to retain the data. Please note that this will be assessed on a case-by-case basis.

After our agreement with you expires or terminates, or our relationship with you has otherwise ended, we may also store your data in an aggregated and anonymised format.

13. California privacy rights

The California Consumer Privacy Act (the “CCPA”) and California Privacy Rights Act (the “CPRA,” and, collectively with CCPA, the “California Consumer Privacy Laws”), provides California residents with certain rights regarding their personal information that is collected by businesses, including the right to request information regarding the collection, use, sale, and disclosure of their personal information, the right to request the deletion of their personal information, and the right to opt-out of the sale of their personal information. This section provides information about the California Consumer Privacy Laws and about the type of personal information we collect and share with other companies. It also explains how you can make requests to us regarding your personal information. Any terms defined in the CCPA (Cal. Civ Code § 1798.140) have the same meaning when used in this section.

(i) Your rights and choices

a. Right to Know What Personal Information is Collected About You and How It Is Used

You have the right to know what categories and specific pieces of personal information we collect about you, the sources from which we collect personal information, our business or commercial purpose for the collection, use, and sharing of your personal information, and any categories of third parties with whom we share your personal information. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• the categories of personal information we collected about you.
• the categories of sources for the personal information we collected about you.
• our business or commercial purpose for collecting that personal information.
• the categories of third parties with whom we share that personal information.
• the specific pieces of personal information we collected about you.

b. Right to Delete Personal Information

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request we will delete, and direct our service providers to delete, your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us, or our service providers, to:

• complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities
• debug to identify and repair errors that impair existing intended functionality.
• engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
• exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• comply with a legal obligation.
• make other internal and lawful uses of that information that are compatible with the context in which you provided it. 

For more information about these and other situations in which we may not delete your information, please see Cal. Civil Code § 1798.105(d).

c. Right to Data Portability 

You have the right to request that we provide you with a copy of personal information we have collected and maintained about you in the past 12 months. California Consumer Privacy Laws allow you to request your information from us up to twice during a twelve (12) month period.  We will provide our response in a readily usable format, which is usually electronic.

d. Right to Correct

You have the right to request that we correct any personal information we retain about you.

e. Right Opt-Out of the Sharing of Personal Information

At the time this Privacy Policy was last updated, we (1) DO NOT SELL personal information; and (2) we DO SHARE personal information for the purpose of cross-context behavioral advertising. You have the right to opt out of the sale or sharing of your personal information, along with the right to opt in to the sale of such information. If we share any of your personal information, you may, at any time, tell us not to share your personal information (see Exercising Your Rights).

f. Exercising Your Rights

To exercise your Right to Know, Right to Data Portability, Right to Correct, or Right to Delete as described above, please submit a verifiable consumer request to us by sending an email to [email protected]

Only you, or your authorized agent, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for a Right to Know twice within a 12-month period. The verifiable consumer request must:

• provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
• describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Making a verifiable consumer request does not require you to create an account with us.

Upon receiving a Request to Know or a Request to Delete, we will confirm receipt within 10 days and provide information about how we will process the request, how we will verify your identity, and when you should expect a response (except in cases in which we have already granted or denied the request). We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

14. Complaints

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at [email protected] and we will endeavour to deal with your request as soon as possible.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address: 

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

15. Changes

We will generally notify you of any material changes to this policy, through a notice provided via the Website or otherwise supplied to you. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued engagement with us after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop your engagement with us.