Privacy Policy

Introduction and summary

At Adrian Gayler Coaching, we are committed to protecting the personal data of the businesses and clients who use our website.

In this Privacy Policy, when we refer to “Adrian Gayler”, “Adrian Gayler Coaching”, “we”, “us” or “our” we mean Monza Capital Ltd and its affiliates in the United Kingdom. When we refer to “you” or “your”, we mean visitors to our website, and individuals connected with corporations (including directors, partners, members, shareholders, and beneficial owners).

This Privacy Policy is important, so please read it carefully. It explains and governs:

  • how and when we collect your personal data, and what information we collect;

  • \what we use your personal data for;

  • who we share your personal data with;

  • how long we hold your personal data for; and

  • your rights to control your personal data.

By accessing and using our website, you need to confirm that you agree to be bound by this Privacy Policy. If you do not, you must immediately cease use of our website, and any services provided by us.

We will amend this Privacy Policy from time to time to comply with applicable laws and regulations or to meet our changing business requirements. You are encouraged to periodically review this page for the latest information on our privacy practices and amendments to our Privacy Policy but if we make changes that we consider to be important or that affect your rights we will let you know.

 

How and when do we collect your information and what do we collect?

If you engage with us in any way, we may collect the following information about you through the methods of contact you choose to use at the point of engagement:

  • information you provide through our website and through our booking processes;

  • information you provide through communications with us, whether in writing (including by letter or email) or on the telephone (including by way of recorded calls); and

  • information we obtain through your engagement with us on social media, including on blogs, forums and through Facebook and X.

If you wish to use our platform, you will need to provide us with the following information, which we sometimes also collect from third parties:

  • your personal details (including name, date of birth, current postal addresses);

  • your contact information (including phone and e-mail details);

    • your business name and contact information;

    • financial information (including bank or building society account details and details of debit cards used to make transfers on the Adrian Gayler Coaching website);

    • information you provide in your dealings with us and through your interaction with our platform;

    • information about your business or company; and

    • passwords and answers to security questions.

In addition to the personal and financial information you submit, or we collect as described above, we will also collect information about your computer (including, where available, your IP address, operating system, and browser type), your interaction with our website, and email performance data.

We also collect and retain:

  • copies of our correspondence with you as well as other data we collect relating to your activities via our website;

  • details about visitors to our website for the purposes of aggregating statistics or reporting purposes; and

  • comments made on blogs and discussion forums in connection with the services we provide.

We generally do not seek to collect sensitive personal data (also known as ‘special categories of data’).

If you provide information about other people, then you must:

  • provide a copy of this Privacy Policy to those persons and ensure that they are aware of and understand its contents; and

  • when providing information about other people, ensure that you have all relevant permissions and authority: (i) to make all those disclosures; (ii) to act on their behalf; and (iii) in respect of those persons.

Using your information

We collect, store, and use your personal data:

  • to inform you of developments and/or changes to our services

  • to develop and improve our services, products and business, and our customer service offering;

  • to comply with our legal and regulatory obligations;

  • to carry out statistical analysis and market research and testing;

  • to contact you (including by SMS and e-mail) with products and services which Adrian Gayler Coaching think may always interest you ( taking into consideration your rights at law including your right to opt-out from receiving marketing from us);

  • for targeted advertising through digital platforms, social media, and television (this may entail profiling, data enrichment and audience segmentation);

  • to verify your identity and the other information you have provided to us, including your bank account information;

  • to update the records we hold about you from time to time;

  • to provide and administer our products and services; and

  • for the prevention and detection of fraud, money laundering, or other illegal or criminal activity.

Where relevant, we will hold and process your sensitive personal data to allow us to make decisions about you and your accounts with us or with which you are connected. This may involve us sharing your sensitive personal data with our regulatory/industry bodies. We will process sensitive personal data only in accordance with our legal rights and obligations. If this processing is carried out with your consent, at the point of collection you will be informed of your right to withdraw that consent at any time, and the process for doing so.

We continually review the legal basis for us using your personal data in the ways described above. In most instances it is in our legitimate interests to use your information in the manner described above to provide you with the services we offer via our platform. We consider this data processing to be proportionate and not prejudicial or detrimental to you. In some, specific circumstances, the processing is necessary for the performance of a contract to which you are a party, necessary for compliance with a legal obligation to which we are subject, or necessary to protect your vital interests. We sometimes rely on consent, and in those instances, we have processes in place to ensure that we obtain your freely given and informed consent to use your personal data for agreed, specific purposes.

o   We use the information we collect about your computer for: (i) our legitimate purposes; (ii) marketing; administration of the products and services we offer; and (iii) service improvement. Our Cookies Policy describes these processes in more detail and explains how we respect your right to privacy when collecting these types of data and do not seek to bypass browser settings set to ‘do not track’ or similar.

Sharing and disclosing your information

We may disclose your personal data to other registered members of our platform:

  • to provide transactional and performance information;

  • We may disclose your personal data:

  • to companies in our group and our affiliates;

  • to our suppliers, sub-contractors and third-party data processors (including card payment and direct debit payment processors, marketing and data analytics service providers, collection agents, tracing agents, insolvency practitioners, professional advisers and persons who provide us with the following services from time to time: identification and fraud check; marketing; technology; product support; and back-up and business continuity);

  • with any third party you have asked us to share your personal data with, including social media sites if you have asked us to connect with your social media account;

  • if we are required to do so by applicable law and regulation or by any governmental, tax, regulatory body, or law enforcement agency; and

  • to any other person with your prior consent to do so.

Third parties who process your personal data on our behalf are only permitted to process your personal data in accordance with our instructions and we take steps to ensure that the transfer and any on-going processing by those third parties is carried out securely and in accordance with applicable privacy laws.

Save as expressly provided above, or otherwise without your consent, we will not share your personal data with any third party.

 

Data Retention

We will not keep your personal data for longer than is necessary for the purposes for which it was collected and is processed and for the purposes of satisfying our legal, accounting, or regulatory reporting requirements. These requirements generally permit us to retain our files for a period of six years after the end of the client  relationship (i.e. the date on which we no longer provide services to you). We may retain data for longer than this in certain circumstances, for example in the event of an ongoing dispute.

False Information and Fraud Prevention Agencies (“FPA’s”)

If we suspect or identify fraud, we may record this and may also pass this information to FPAs (such as CIFAS), and other organisations involved in crime and fraud prevention including law enforcement agencies. We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

We and fraud prevention agencies process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify your identity to comply with our legal and regulatory obligations and to protect us and users of our platform. Such processing is a legal requirement if you request to invest or borrow through our platform.

We and other organisations may access and use this information to prevent fraud, money laundering or other criminal activity (for example, by checking details on credit applications, for managing credit and recovering debt). We also use FPAs to screen job applicants and employees.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services you have requested, or we may stop providing existing services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing, or employment to you.

Whenever fraud prevention agencies transfer your personal data outside the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to “international frameworks” intended to enable data sharing.

Please contact us if you want to receive details of the relevant fraud prevention agencies.

 

The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by Adrian Gayler Coaching.

In particular, Users have the right to do the following, to the extent permitted by law:

  • exercise your right to request access to certain personal data records we hold about you (a subject access request), by emailing hello@adriangayler.com with the subject line “subject access request”;

  • request that we update and correct any out-of-date or inaccurate personal data we hold about you by emailing us at hello@adriangayler.com with the subject line “data update request”;

  • contact us to register your preferences for how we contact you at hello@adriangayler.com or by calling us on 07702764516;

  • opt out of any marketing communications that Adrian Gayler Coaching may send you by emailing us at hello@adriangayler.com by calling us on 07702764516, by writing to our Data Protection Officer at Pen y Dre Cottage, Brecon Road, Crickhowell, Powys, NP8 1DG or by following the link on any email marketing you have received or by following the appropriate opt-out procedures that we include on all marketing materials;

  • exercise your right to object to our continued processing or your right of erasure, neither of which is a guaranteed or absolute right. We will consider all requests of this nature and consider any compelling legitimate grounds to continue processing, for example our need to continue to process your personal data in connection with any legal or regulatory requirements to which we are subject.

When you contact us, we will need you to provide us with adequate information to identify yourself to enable us to assist you in fulfilling your request. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will deal with your request as soon as possible and will keep you updated.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Adrian Gayler Coaching or for the purposes of the legitimate interests pursued by the Adrian Gayler Coaching, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Adrian Gayler Coaching is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Adrian Gayler Coaching in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Adrian Gayler Coaching may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Your Rights

You may, at any time:

  • exercise your right to request access to certain personal data records we hold about you (a subject access request), by emailing hello@adriangayler.com with the subject line “subject access request”;

  • request that we update and correct any out-of-date or inaccurate personal data we hold about you by emailing us at hello@adriangayler.com with the subject line “data update request”;

  • contact us to register your preferences for how we contact you at hello@adriangayler.com or by calling us on 07702764516;

  • opt out of any marketing communications that Funding Circle may send you by emailing us at hello@adriangayler.com by calling us on 07702764516, by writing to our Data Protection Officer at Pen y Dre Cottage, Brecon Road, Crickhowell, Powys, NP8 1DG or by following the link on any email marketing you have received or by following the appropriate opt-out procedures that we include on all marketing materials;

  • exercise your right to object to our continued processing or your right of erasure, neither of which is a guaranteed or absolute right. We will consider all requests of this nature and consider any compelling legitimate grounds to continue processing, for example our need to continue to process your personal data in connection with any legal or regulatory requirements to which we are subject.

When you contact us, we will need you to provide us with adequate information to identify yourself to enable us to assist you in fulfilling your request. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will deal with your request as soon as possible and will keep you updated.

Security and other Third Parties

Adrian Gayler Coaching takes appropriate technical and organisational measures to safeguard the personal data that you provide to us, but we accept no liability if communications are intercepted by third parties or incorrectly delivered or not delivered.

If we transfer your information to third parties, we will take steps to ensure that the transfer and any on-going processing by those third parties is carried out securely and in accordance with applicable privacy laws.

Our website contains links to other websites operated by third parties. This Privacy Policy applies only to the personal data that Adrian Gayler Coaching collects and we are not responsible for personal data that third parties may collect, store, and use through other websites.

You also have a responsibility to ensure that your information is kept secure. If you have an online account with us, you must:

  • keep your login details secret;

  • log out of your account when not using it;

  • maintain good internet security (for example, be careful when using public WiFi or shared access internet connections); and

  • tell us immediately if you think your account has been compromised.

Contact Details


If you have any questions or concerns about this Privacy Policy, how we process your personal data, or if you wish to exercise any of your rights as a data subject, you can contact us at hello@adriangayler.com. Alternatively, you can write to us at Pen y Dre Cottage, Brecon Road, Crickhowell, Powys, NP8 1DG. Please be sure to mark all correspondence for the attention of our Data Protection Officer so that we can get back to you quickly.

If you have concerns about how we manage your personal data, you can make a complaint to the UK Data Protection Authority, the Information Commissioner’s Office. You can find their contact details here: https://ico.org.uk/global/contact-us/.

 

About Adrian Gayler Coaching

Adrian Gayler Coaching is operated by:  Monza Capital Ltd, a company incorporated in England and Wales, with registered number 06968588 and registered office at Pen y Dre Cottage, Brecon Road, Crickhowell, Powys, NP8 1DG.

Monza Capital Ltd is registered with the Information Commissioner with registration number [TBC].