Your privacy is very important to us. This policy sets out certain information about what personal data we process about you, why we process it and how we handle it.

​

About us

​

We are Michelle Sciama Associates Limited (company number: 09629055) (“we”, “us”, “our” and “ours”). We act as data controller in respect of the personal data you provide to us.

​

The personal data we collect and how we collect it

We process various items of personal data in order to provide our high performance coaching, training and business strategy consultancy services to clients. Where our client is a company or other corporate body the personal data we may process includes that of our client’s directors, shareholders and employees. Typically the personal data we collect and process includes names, addresses, email and telephone contact details (including personal and/or, where the name of the recipient is specified, business contact details), and other personal data pertinent to the services we are engaged to provide. We may also process your personal identification information (such as your passport or other photographic identification), date of birth, details of your employment, financial affairs, family and family relationships, your relationship to our client (where you are not our client), your psychometric test results and your use of our website, www.michellesciama.com.

​

In limited circumstances we may also process certain special categories of personal data about you, such as your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, gender, health and sex life or sexual orientation where we require this information to fulfil our services.

​

The personal data we collect about you will generally be provided to us directly by you (whether over the phone, in person, by email, your completion of any questionnaires or contact forms, by using any of our social media sites or otherwise), but may also be provided to us by a client or their representative in the course of our provision of services and in other cases may be collected from publicly available resources. If you engage with us on social media, we may receive your name and other profile information that you make publicly available.

​

You may also provide your personal data to us when submitting an enquiry through our contact form on our website or when signing up to our mailing list.

​

Why we process your personal data

We collect and process personal data about our clients, prospective clients, referrers, other professionals, suppliers and other third parties and, if applicable, their personnel and other representatives, for the following purposes:

​

• the performance of our contractual engagements (or potential contractual engagements) with and services for clients (whether written or verbal and including taking initial steps to deal with enquiries);

• compliance with legal obligations;

• to pursue our legitimate interests of the development of our business (for example retaining contact information for referrers and other professionals for carrying out client services or the mutual development of business opportunities);

• the establishment, exercise, resolution and/or defence of legal claims; or

• for direct marketing, which we will generally only do with your consent.

​

Who we share your personal data with

We may share your personal data, where necessary, with:

• our IT and technical service providers, platforms and applications;

• our insurers and insurance brokers, auditors and other professional advisors;

• any PR and/or marketing agencies we may engage from time to time;

• any payment processors we may use in respect of any online purchases of webinars or other online training services;

• the business psychology and personality assessment providers we use;

• regulators, government agencies, accreditation bodies and other authorities.

​

We may also share your data with third parties in the following circumstances:

 

• if we are under a legal or regulatory duty to do so;

 

• if it is necessary to do so to enforce our terms of use or other contractual rights;

 

• to lawfully assist the police or security services with the prevention and detection of crime or terrorist activity;

 

• where such disclosure is necessary to protect the safety or security of any persons;

• in the event that we sell or buy any business or assets, with the prospective seller or buyer of such business or assets and their advisors;

• if we or substantially all of our assets are acquired by a third party, with such third party and their advisors (as the personal data held by us about our clients will be one of the transferred assets).

​

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-party service providers 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.

​

Transfers outside of the European Economic Area (EEA)

​

Where any of our third party service providers are located outside of the EEA, we will only disclose your personal data to such party provided that the transfer of such data outside of the EEA is undertaken in compliance with the data protection legislation to which we are subject which will generally be where the country has been deemed to provide an adequate level of protection by the European Commission or where we have a specific contract in place with terms approved by the European Commission.

​

Please note that one of the business psychology and personality assessment providers we use, NeuroColor LLC, is located in the United States.

​

What we do to protect your personal data

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.

​

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk.

​

Email Marketing

If you have opted in to receiving marketing communications and provided your name and email address for this purpose, we may process this personal data to contact you with news and information about our services on the basis of your consent. You are able to withdraw your consent to such processing at any time by either contacting us at michelle@michellesciama.com or by following the “opt-out/unsubscribe” option in any email marketing communication we send to you.

​

Retention of your personal data

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.

​

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

​

The time periods vary depending on the particular circumstances, but one of the following specific periods are most likely to apply to you:

​

• If you (or your employer) are a client or third party whose personal data we are holding in relation to a specific engagement of our services, we will hold your information in relation to such engagement for up to 6 years following the conclusion of the relevant engagement;

• If you have opted in to receiving marketing communications, we will retain your personal data for the purpose you have consented to unless you withdraw your consent or, if you do not open any of our emails for a period of more than 24 months, we may choose not to keep your personal data for this purpose.

​

• If you have made an enquiry through our website contact form or otherwise and you (or your employer) do not become a client of ours, we will delete your information after 6 months.

​

We do not retain (other than within our own social media profiles) or export to our system any personal data we obtain from your social media profile for any purpose. If you would like any further specific information regarding how long we hold your personal data, please contact us using the details below.

​

Please be aware that other terms may apply to you.

Our website and emails we send to you may contain links to and from third-party websites, plug-ins and apps (in particular those of the business psychology and personality assessment providers we use. 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 apps and we do not accept any responsibility or liability for their privacy policies. When you leave our websites or click on any link from our emails, we encourage you to read the privacy notice of every website and app you visit before submitting any personal data.

​

Cookies

When you visit our website, we use certain cookies to improve your browsing experience. 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 our website may become inaccessible or not function properly. For more information about the cookies we use, please refer to our website provider wix.com cookie policy. 

​

Your rights

You have the right to withdraw your consent to us using your personal data at any time where you have provided any special categories of data to us by contacting us using the details below (although we may not be able to fully provide our services to you or our client if you ask us to stop processing any special category data which is relevant to our engagement).

​

You also have the right to withdraw your consent to email marketing as set out above.

You have the following rights in respect of your personal data:

• a right to access a copy of the personal data we hold about you;

• a right in certain circumstances to request a transfer of your personal data to you or a third party;

• a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed;

• a right to object to our processing of your personal data in certain circumstances where we are relying on our legitimate interests as our lawful basis for processing your personal data;

• a right to object to processing for direct marketing.

​

You can exercise any of these rights by contacting us using the details below. 

​

​

Your right to make a complaint in respect of our use of your personal data.

You have the right to complain in respect of our use of your personal data. If you are a UK resident, your complaint should be addressed to the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us first before you escalate your complaint.

​

You can contact us in respect of your personal data.

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to michelle@michellesciama.com 

​

Changes to this privacy policy and your personal data

We may update this policy from time to time by updating the version on our website at michellesciama.com/privacypolicy.

It is important that the personal data we hold about you is accurate and up to date and so please keep us informed of any changes to your personal data during our relationship with you.