Privacy, cookies and terms

Privacy Notice

This notice explains how we collect and use your personal data when you visit this website, get in touch, book a call or work with Philly as a client, and the rights you have under UK data protection law (the UK GDPR and the Data Protection Act 2018).

1. Who we are

Clear Focus Consulting Ltd, trading as Philly Fuggle (“we”, “us”, “our”), is the controller of your personal data. Our details are above. For anything about your data, contact us via the contact form on our website or by post to Clear Focus Consulting Ltd, 62 Broad Street, Ely, Cambridgeshire, CB7 4BE.

2. The data we collect

• Enquiries: your name, email address, phone number if you give it, and whatever you tell us when you email, message us on social media, use the contact form on this site or book a call. If you choose to answer the optional “How did you hear about me?” question on the contact form, we also keep your answer.
• Email sign-ups: if you sign up for emails or for a free live group session, your email address, your first name if you give it, whether you ticked the box to receive emails, and the date you signed up.
• Client information: if you work with Philly, your contact details, the goals and notes from our sessions, and booking and payment records. We never see or store your full card details.
• Health and wellbeing: during coaching you may choose to tell us about things like stress, anxiety or other health matters. This is “special category” data. We only record it with your explicit consent, only where it helps your coaching, and you can withdraw that consent at any time.
• Testimonials: if you give us a testimonial, we publish it only with your permission, and only with the name, photo and wording you have agreed.
• Technical data: when you visit, our hosting provider automatically handles standard technical information (such as your IP address, browser type and the pages requested) so the site can be delivered and kept secure. We do not use analytics, advertising or tracking tools on this website.

3. Why we use it and our lawful basis

• To reply to your enquiry and arrange a call: our legitimate interest in answering people who contact us, or steps you have asked us to take before entering into a contract.
• To understand how people hear about us, from your optional answer on the contact form: our legitimate interest in knowing which ways of reaching people work, without using cookies or tracking.
• To send you a free live group session invite and occasional emails about free group sessions, coaching and ideas to help you get unstuck and be unstoppable, when you sign up for them: your consent, which you give by ticking the box when you sign up. You can withdraw it at any time by using the unsubscribe link in any email we send, or by telling us through the contact form on our website. If you only sign up for a live session, we use your details just to send you the joining link and a reminder, as you asked.
• To provide coaching you have booked: performance of our contract with you.
• To record health or wellbeing information you share in sessions: your explicit consent.
• To keep business, accounting and tax records: our legal obligations.
• To run this website and keep it secure: our legitimate interests.
• To publish your testimonial: your consent.
• To send you news or offers by email: only if you have opted in, or if you are a client and we tell you about similar coaching services, with an easy way to opt out in every message. You can unsubscribe at any time.

We do not sell your data, and we do not make decisions about you by automated means or profiling.

4. Who we share it with

We only share your data where needed, with:

• the company that hosts this website, and our email provider;
• FormSubmit (formsubmit.co), which forwards messages sent through the contact form, and for now live session sign-ups, on this website to our email, if you use them. FormSubmit acts as our data processor and may process your data outside the UK;
• MailerLite (mailerlite.com), which runs our email list: it stores the details you give when you sign up for emails and sends our emails, including the email asking you to confirm your sign-up. MailerLite acts as our data processor and is based in the EU;
• Calendly (calendly.com), which runs our booking calendar: it stores the details you give when you book a call and sends your confirmation and reminders. Calendly acts as our data processor and may process your data outside the UK;
• a video-call service, if you attend a call through one, and a payment provider if you pay for coaching;
• our professional advisers (such as accountants, lawyers and insurers), and authorities where the law requires it.

These providers act on our instructions and must keep your data secure. If you contact us on Facebook, Instagram or LinkedIn, those platforms also handle your data under their own privacy policies.

5. International transfers

Some of our providers may store data outside the UK, for example in the USA. Where they do, we make sure the transfer is protected by UK law: either the country (or, in the USA, the provider’s certification under the UK Extension to the EU-US Data Privacy Framework) is covered by UK adequacy regulations, or the provider has signed the ICO’s International Data Transfer Agreement or the UK Addendum to the EU standard contractual clauses.

6. How long we keep it

• Enquiries that don’t lead to working together: up to 12 months after our last contact.
• Email sign-ups: until you unsubscribe. After that we keep only your email address on a “do not email” list, so we never email you again by mistake.
• Client records, including session notes: for as long as we work together and then up to 6 years, in case of questions, complaints or legal claims, after which they are securely deleted.
• Accounting and tax records: 6 years, as the law requires.

7. Keeping it safe

We use appropriate security, such as password-protected accounts and reputable providers, and only people who need your data can access it. If a data breach happens that puts you at risk, we will tell you and the ICO where the law requires it.

8. Your rights

You have the right to ask for a copy of your data, to have it corrected or deleted, to restrict or object to how we use it, to have it transferred to you or someone else, and to withdraw consent at any time (this doesn’t affect anything we did before). You can always object to direct marketing. Just contact us via the contact form on our website or by post to Clear Focus Consulting Ltd, 62 Broad Street, Ely, Cambridgeshire, CB7 4BE; it is usually free, and we will reply within one month. We may need to check your identity first.

If you are unhappy with how we have handled your data, please tell us so we can try to put it right. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK data protection regulator: ico.org.uk/make-a-complaint or 0303 123 1113.

9. Other websites

This site links to other websites, such as social media. They have their own privacy policies, and we are not responsible for them.

10. Changes

We will update this notice when how we use your data changes, and show the date at the top.

Cookie Policy

Cookies are small files a website can save on your device. Under UK law (the Privacy and Electronic Communications Regulations), a site must ask your consent before using any cookies that are not strictly necessary.

Cookies on this website

This website does not set any cookies and does not use similar technologies such as local storage, tracking pixels, analytics or advertising tools. Our fonts and images are served from this site itself, not from third parties, so visiting does not share your details with font or advertising companies. That is why there is no cookie banner.

Other websites

If you click through to social media, an online booking page or another website, that site may set its own cookies under its own policy.

Our contact form, and for now our live session sign-up form, send what you type to FormSubmit (formsubmit.co), which forwards it to us by email. These forms do not set cookies on this website; when you press send, your browser briefly visits FormSubmit’s own site, which may set its own cookies under its own policy, before returning you here.

Our email sign-up form sends your first name (if you give it) and email address straight to MailerLite (mailerlite.com) when you press the button. It does not set cookies on this website, and you stay on this page.

Our booking page shows Philly’s calendar from Calendly (calendly.com), so you can choose a time without leaving this site. The calendar is loaded from Calendly, which may set its own cookies under its own policy and may show you its own cookie choices. If you’d rather not load it, please use the contact form on our website to arrange a call instead.

If this changes

If we ever add something else that uses non-essential cookies, such as visitor statistics or an embedded video, we will update this policy and ask for your consent before those cookies are set.

Controlling cookies

You can see, block or delete cookies in your browser’s settings at any time. Questions: please use the contact form on our website.

Acceptable Use Policy

This policy, together with our Terms of Use, sets out how you may use this website, which is run by Clear Focus Consulting Ltd, trading as Philly Fuggle.

You must not use this site

• in any way that breaks any law or regulation, or for anything fraudulent;
• in any way that may harm a child;
• to send unsolicited advertising or spam;
• to copy or reuse our content in breach of our Terms of Use;
• to introduce viruses or any other harmful code, or to try to gain unauthorised access to the site, its server or any connected system;
• to attack the site, for example with a denial-of-service attack.

Messages you send us

Anything you send through this site must not be defamatory, obscene, offensive, hateful or threatening, must not infringe anyone’s rights, and must not impersonate anyone or mislead.

Breaches

If this policy is breached, we may block access to the site, report the matter to the authorities and take any other reasonable action, including legal action.

Changes

We may update this policy from time to time; the date at the top shows the latest version.

Terms of Use

These terms apply to your use of this website. By using it, you agree to them. They do not cover paid coaching, which is agreed with you separately.

About us

This website is run by Clear Focus Consulting Ltd, trading as Philly Fuggle, registered in England and Wales under company number 10331455, with its registered office at 62 Broad Street, Ely, Cambridgeshire, CB7 4BE. You can contact us via the contact form on our website or by post at our registered office.

Using the site

The site is free to use. We may change, suspend or withdraw it at any time, and we cannot promise it will always be available or error-free. You must follow our Acceptable Use Policy.

Our content

We own, or are licensed to use, everything on this site, including text, photographs, testimonials and design. You may view it and share links to it for personal use, but you must not copy or reuse it for commercial purposes without our written permission.

Information, not advice

The content of this site is general information about Philly’s coaching. It is not medical, psychological, financial or legal advice, and coaching is not a substitute for care from a doctor or other qualified professional.

Links

Links to other websites are for convenience only; we have no control over them and are not responsible for their content. You may link to our site as long as you do it fairly and legally, and do not suggest any association or endorsement that does not exist.

Your personal data

We handle your personal data as described in our Privacy Notice.

Our responsibility to you

Nothing in these terms limits or excludes our liability for death or personal injury caused by our negligence, for fraud or fraudulent misrepresentation, or for anything else that cannot be limited or excluded under English law, including your rights as a consumer under the Consumer Rights Act 2015. Because the site is free and for general information, we are not liable for any business losses (such as loss of profit, income or business opportunity) arising from its use.

Changes

We may update these terms from time to time; the date at the top shows the latest version.

Law and courts

These terms are governed by the law of England and Wales. Any dispute will be dealt with by the courts of England and Wales, except that if you live in Scotland or Northern Ireland you may also bring proceedings in your local courts.