Privacy Policy

Last Updated: February 20, 2023

Welcome to Tapping Into Choice!

Please read this Privacy Policy (“Policy”, “Privacy Policy”) carefully before using the www.tappingintochoice.com website or any of its services (the “Service”) operated by Tapping Into Choice (“us”, “we”, or “our”).

Your privacy is important to us. It is our policy to respect your privacy regarding any information we may collect from you across our Service. This Policy describes and governs the information collection, use, and sharing practices of Tapping Into Choice with respect to your use of our Service. This Policy applies to all visitors, users and others who wish to access or use the Service.

Consent

We use your Personal Information for providing and improving the Service. Before you use or submit any information through or in connection with the Service, please carefully review this Privacy Policy. By using any part of the Service, you acknowledge that you understand that your information will be collected, used, and disclosed as outlined in this Privacy Policy and that you agree to be bound by this Policy. If you do not agree to be bound by the terms and conditions of this Policy, you are not permitted to continue to access or use this Service.

Purpose

This policy sets out how we are committed to being accountable for how we use and protect the information you provide when accessing and using the Service. We aim to ensure any data you provide is kept securely, managed respectfully and only used for the purposes for which it has been provided. This Policy will be updated periodically in line with current legislation. It explains what personal information we may collect and what we will do with it and not do with it and who will or won’t have access to it and under what conditions. It also explains your rights with regard to your personal information and our cookie policy. We will not use or share your information with anyone except as described in this Privacy Policy.

Adherence

Tapping Into Choice is based in British Columbia, Canada and is governed by the BC’s Personal Information Protection Act (PIPA) and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).

For users in the European Union and the United Kingdom, this Privacy Policy also adheres to the General Data Protection Regulation (GDPR).

Legal bases for processing

We will process your personal information lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so. We collect and use your information only where:

It’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us);
You give us consent to do so for a specific purpose.
We need to process your data to comply with a legal obligation

Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).

Information we collect and how we use it

We will only collect, use, or disclose the minimum amount of personal information that is necessary to fulfill the purpose of the collection as set out in this Privacy Policy. We will not collect, use or disclose any additional data beyond the data listed below without notifying you first.

Log data

When you visit the Service, our servers may automatically log the standard data provided by your web browser. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details. This is being used for analytics and to provide the Service’s features.

Personal information

When you contact us via the Service or email we may collect your:

1) Name;

2) Email Address;

3) Telephone/mobile Number;

4) Any information you choose to supply regarding the purpose of your enquiry.

This information is being used in order to make contact with you to discuss your requirements.

If you make an appointment, you will be given a copy of this Privacy Policy so that you are aware in advance how the information provided will be used in the course of our sessions together.

At or after our first meeting you will be asked to sign your consent to this Privacy Policy and to complete a Client Form & Contract.

You will also be asked to provide your GP contact details and some basic health information. The purpose of this information is to help make sure we are a good fit for working together, and sometimes there are circumstances where it may be necessary to contact your GP before commencing our sessions. You will be informed of this at our first appointment should this appear appropriate. You will also be asked to provide the details of your next of kin. This is used only in emergency situations or where you have specifically requested that your next of kin be contacted.

In the course of our sessions notes will be kept with the intention of providing a consistent and effective service.

After a session you will be emailed a payment invoice using a third party service that will process payment and in the process will collect payment information from you. For the purposes of clarity, we do not receive or retain your bank details.

In line with our ethical standards we do not contact our clients or potential clients for promotional purposes. We will only contact a potential client when they have requested it themselves or for the purposes of arranging and re-arranging appointments requested by them and to generally and appropriately communicate with clients in the normal course of administering a coaching service. We do not send newsletters.

Disclosure of personal information to third parties

We may disclose personal information to:

Third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers and payment systems operators;
Courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights.

International transfers of personal information

Your information, including Personal Information, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. These locations include but are not limited to Canada and the Unites States.

Please note that the GDPR permits transfer of personal data outside the European Union in some cases if the country has adequate level of data protection. Canada and BC currently have adequacy status with the European Union, which will continue until reviewed by the European Commission. This means that the European Commission recognizes Canada and BC as having an adequate level of privacy protection in comparison to the GDPR and permits transfers of information about European Union citizens to Canada and BC as though those transfers were within the European Union.

The USA is in the process of an adequacy status review and a draft adequacy decision concluded that the United States ensures an adequate level of protection for personal data transferred from the European Union to the US.

Any transfer of personal information from countries in the European Union to a third country outside the European Union - which does not ensure an adequate level of protection according to the European Commission - will be undertaken in accordance with the current and updated set of Standard Contractual Clauses, as approved by the European Commission.

Your consent to this Privacy Policy followed by your submission of your information represents your agreement to that transfer.

Safeguarding and Retention

We retain the information we collect for as long as necessary to fulfill the purposes set forth in this Privacy Policy or as long as we are legally required or permitted to do so. After sessions are terminated, in line with the requirements of our Governing Bodies, we will retain your records for 7 years on computer or hard copy. After that period of time has passed, we will shred any paperwork and dispose of any computerised information.

While we retain your information, we will protect it within commercially acceptable security safeguards, to prevent loss and theft, as well as unauthorized access, collection, use, disclosure, copying, modification, disposal, destruction, or similar risks. That said, we advise that no method of transmission over the internet, or method of electronic storage is 100% secure. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the absolute security of user data beyond what is reasonable practical.

If we learn that you are affected by a data breach we will notify you within 72 hours of discovering the breach.

Your rights and controlling your personal information

You have various rights with respect to the collection and use of your information through the Service. Those are as follows:

Choice and consent: By providing personal information to us, you explicitly consent to us collecting, holding, using and disclosing your personal information in accordance with this Privacy Policy. You do not have to consent to the collection of information, however, if you choose not to provide it we may not be able to work with you.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Right to be informed (which is why we have produced this Policy).

Right of access: You may request details and/or a copy of the personal information that we hold about you. If you wish to see your file then please make a request in writing. You can use the contact us link at the end of this Policy. We will provide you with the information within 30 days of your request. You may be required to prove your identity before given access to your personal information.

Right to rectification: This is your right to request changes to any information we hold that is factually inaccurate. If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the link at the end of this Policy and we will make the relevant changes.

Right to erasure: You may request that we erase the personal information we hold about you at any time. Given the requirements of our Governing Bodies, we are required to hold your details for a period of 7 years, after this your information will be securely destroyed.

Right to restrict processing: You may require that we will restrict processing your data until any complaint is resolved.

Right to data portability: You may request that we transfer your personal information to another third party. If you ask us to transfer the information we hold to a third party then we will do so. We will not share your information without your specific consent, other than in the situations described above.

Right to object to data processing activities: You have the right to object to us using your personal data for any particular purpose. We will not contact you for marketing purposes.

Right not to be subject to automated decision-making including profiling: We are not using automated decision-making and we will not use your information for profiling purposes.

Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the link at the end of this Policy and provide full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of the investigation and the steps we will take to deal with your complaint. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority but we encourage you to contact us so that we may resolve your concerns directly as best and as promptly as we can.

Confidentiality and Data Protection

We uphold the common law principles of confidentiality where the duty to keep confidence is balanced against the concept of ‘greater good’. If, in our opinion, there is good reason to believe that not to disclose certain information would cause serious danger or harm to the client, to me (as the coach) or to others then a GP or other appropriate agencies may be contacted. Only information required to ensure safety of relevant parties would be disclosed. Information may have to be disclosed without consent for the prevention, detection or prosecution of a crime. We cannot withhold information where there is a Court Order. The sharing of anonymous case histories with mentors and peer support groups is not a breach of professional confidentiality.

Children’s Privacy

The Service is intended for users who are at least of an age of majority. If you are under the age of majority, you cannot use or register to use this Service so please do not provide your personal information

We do not knowingly collect personal information from minors. If you are a parent or guardian and you learn that your children have provided us with Personal Information, please contact us.

If we become aware that we have collected personal information from a minor, the personal information will be deleted as soon as possible.

Cookies

We use “cookies” to collect information about you and your activity across our Service. A cookie is a small piece of data that the Service stores on your computer when you visit the website, so that it can enable certain features and analyse web traffic to the Service. It is being accessed each time you visit, so we can understand how you use the Service. Through this we can see which of the website's pages are being viewed.

Most web browsers automatically accept cookies but you can modify your settings to decline them if you prefer by instructing your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you choose to do this, you may find that you cannot make full use of the Service.

Please refer to our Cookie Policy for more information.

Limits of our policy

The Service may, from time to time, contain links to other websites of interest that are not operated by us. However, once you use these links please be aware that you have left the Service and we do not have any control over other websites. We cannot be held responsible for the protection and privacy of any information which you provide when visiting such sites and these sites are not governed by our Privacy Policy. Please exercise caution and look at the privacy statement applicable to the website you are visiting.

Changes to this Policy

This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will post any changes here and will revise the date last updated at the top of this Privacy Policy. We recommend that our users periodically review the Privacy Policy to ensure that they are notified of any updates.

If we make a material change to this Privacy Policy, for example changing a lawful basis on which we process your personal information, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website. We will also ask you to re-consent to the amended Privacy Policy.

Your continued use of the Service after any changes to this Policy will be regarded as your acknowledgment of the modifications and your consent to abide and be bound by our modified practices around privacy and personal information. If you do not agree to be bound by the terms and conditions of the new Privacy Policy, you are no longer authorized to use the Service.

Questions about this Privacy Policy

If you have any questions about this Privacy Policy or our privacy practices, or have any concerns or complaint about the way we handle your personal information, or to seek to exercise your privacy rights in relation to the personal information we hold about you, you may contact our Data Controller who is also our Data Processor here.

Tamar Genossar

Helping you live a life of choice