This is the privacy notice of Karen Pratt, trading as TA Matters (‘I’, ‘my’, or ‘me’). If you have any concerns about this notice or your privacy please tell me. You can contact me through this website or by email.

Introduction

This notice describes how I process your personal information. It tells you about your privacy rights and how the law protects you. In the context of the law and this notice, ‘personal information’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal information, including collecting, storing, transferring and using it is referred to as ‘processing’. I am committed to protecting your privacy and the confidentiality of your personal information. I undertake to preserve the confidentiality of all information you provide to me and I hope that you reciprocate.

Personal information I process

How I obtain personal information

The information I process about you includes information:

  • you directly provide to me
  • I collect as a result of monitoring how you use this website

Types of personal information I process directly

When you book a course, coaching session or supervision session, or if you contact me, you may provide personal information to me. This may include:

  • personal identifiers, such as your first and last names, your title and your date of birth
  • contact information, such as your email address, your telephone number and your postal address
  • information about your personality as it is needed for our contracted work together
  • transaction information, such as information about payments and courses and sessions you have booked and attended
  • records of communication between us including messages sent through this website, email messages and telephone conversations
  • your preferences and requests regarding the treatment of your personal information in respect of privacy

Types of personal information I collect indirectly from your use of this website

When you visit this website, I process:

  • technical information about the hardware and the software you use to access this website, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
  • usage information, including the frequency you use this website, the pages that you visit, whether you receive messages and whether you reply to those messages

Use of aggregated information

I may aggregate anonymous information such as statistical or demographic information for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal information but is not considered as such in law because it does not reveal your identity. However, if I combine or connect aggregated information with your personal information so that it can identify you in any way, I treat the combined information as personal information, and it will be used in accordance with this privacy notice.

Special personal information

Special personal information is information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric information. In providing my services to you, I may process information that falls into the types classed as special personal information. Under law, I am able to process special category information where you have given explicit consent for me to do so. If you do not consent to my processing of it, you should tell me as soon as possible. If I process special category information relating to you then I ensure that additional care is given in safeguarding it.

Membership of professional bodies

I am a member of both the International Coaching Federation (‘ICF’) and the International Transactional Analysis Association (‘ITAA’). In addition to following the requirements of the law, the ICF requires me as a member to comply with its code of ethics, which includes principles relating to the confidentiality and privacy of client information. The code can be found at: https://coachingfederation.org/ethics/code-of-ethics

If you do not provide required personal information

Where I need to collect personal information by law, or in order to be able to provide services under a contract I have with you, and you fail to provide that information when requested then I may not be able to perform that part of or all of that contract. If so, I will notify you of this at the time.

The bases on which I process information about you

The law requires me to determine under which of six defined bases I process different categories of your personal information, and to notify you of the basis for each category. If a basis on which I process your personal information is no longer relevant then I shall immediately stop processing your information. If the basis changes then if required by law I shall notify you of the change and of any new basis under which I have determined that I can continue to process your information.

Information I process because I have a contractual obligation with you

In order to provide my services, or in situations where you have requested that I provide my services, I must collect and record your personal data. For example, when you book a coaching session as a new client I reasonably presume you do so with intention to enter into a contract. In this situation, your personal data which includes personal identifiers and contact information is processed on the basis of contractual obligation. I continue to process this information until the contract between us ends or until I am otherwise no longer required to keep it.

Information I process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse this website or ask me to provide you with more information about my services, you provide your consent to me to process information that may be personal information. Wherever possible, I aim to obtain your explicit consent to process this information, for example, by asking you to agree to the use of cookies when you first visit this website. I continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists. You may withdraw your consent at any time by visiting our Cookie Declaration page. You can also contact us regarding your personal information from our Personal Information Request page.

Information I process for the purposes of legitimate interests

I may process information on the basis there is a legitimate interest, either to you or to me, of doing so. Where I process your information on this basis, I do after having given careful consideration to:

  • whether the same objective could be achieved through other means
  • whether processing (or not processing) might cause you harm
  • whether you would expect me to process your information, and whether you would, in the round, consider it reasonable to do so

For example, I may process your information on this basis for the purposes of:

  • record-keeping for the proper and necessary administration of my business
  • protecting and asserting the legal rights of any party
  • insuring against or obtaining professional advice that is required to manage business risk
  • protecting your interests where I believe I have a duty to do so

Information I process because I have a legal obligation

Sometimes, I must process your information in order to comply with a statutory legal obligation. For example, I may be required to give information to legal authorities if they so request or if they have the proper authorization such as a search warrant or court order. This may include your personal information.

Information processed through automated systems when you visit this website

Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date. They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered. They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history. Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate. The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website. When you first visit this website, I ask you whether you wish me to use cookies. If you choose not to accept them, I shall not use them for your visit except to record that you have not consented to their use for any other purpose. If you choose not to use cookies or you prevent their use through your browser settings, you may not be able to use all the functionality of this website. The cookies I use and their attributes are described in more detail in our Cookie Declaration.

Delivery of services using third party communication software

With your consent, we may communicate using software provided by a third party such as Facebook (WhatsApp), Apple (Facetime), Microsoft (Skype) or Zoom Video Communications (Zoom). Such methods of communication should secure your personal data using encryption and other technologies. The providers of such software should comply with all applicable privacy laws, rules, and regulations, including the Protection of Personal Information Act (‘POPIA’). If you have any concerns about using a particular software for communication, please tell me.

Personal identifiable information from your browsing activity

Requests by your web browser to the servers for these web pages and other content on this website may be recorded. I may record information such as your geographical location, your Internet service provider and your IP address. I may also record information about the software you use to browse this website, such as the type of computer or device and the screen resolution. From time to time, I use this information in aggregate to assess the popularity of the webpages on this website and how I perform in providing content to you. If combined with other information I know about you from previous visits, the information possibly could be used to identify you personally, although I do not use it in such a way.

Control over your own information

Your duty to inform me of changes

It is important that the personal information I hold about you is accurate and current. Please keep me informed if your personal information changes.

Access to your personal information

At any time you may review or update personally identifiable information that I hold about you. To obtain a copy of any information you should contact me to make that request. After receiving the request, I will tell you when I expect to provide you with the information, and whether I require any fee for providing it to you.

Removal of your information

If you wish me to remove personally identifiable information from my records you should contact me to make your request. This may limit the service I can provide to you.

Objection to my use of your information

You have a right to object to my processing of your personal information. If you do so, I shall, whenever possible, no longer process that personal information. However, should I assess that there is a legitimate basis why I need to continue to process the information, I shall notify you of that basis and of the information I shall process under that basis. If you object to my processing of your personal information, I may no longer be able to provide my services to you.

Verification of your information

When I receive any request to access, edit or delete personal identifiable information I shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information. You may send a request by visiting our Personal Information Request page.

Other matters

Information may be processed outside South Africa

This website is hosted in the Republic of South Africa (‘the Republic’). I may also use outsourced services in countries outside the Republic from time to time in other aspects of my business. For example, I may use services from Google, which may be hosted in the United States of America. Accordingly, information obtained within the Republic or any other country could be processed outside South Africa. Where I use services that may process information outside of the Republic, I take steps to safeguard your personal information by ensuring that those service providers comply with the same obligations as I must under South African law. Such obligations are included in the contracts between me and the processor.

Communicating

When you contact me, I collect the information you have provided in order to reply. I may keep personal information associated with your message, including your personal identifiers and contact information so as to be able to respond to you.

How you can complain

If you are not happy with this privacy policy or if you have any complaint regarding how I process your personal information then you should tell me. When I receive a complaint, I record all the information you have given to me. That information may itself comprise personal information. I use that information to resolve your complaint. If your complaint reasonably requires me to contact some other person, I may decide to give to that other person some of the information contained in your complaint. I do this as infrequently as possible, but it is a matter for my sole discretion as to whether I do give information, and if I do, what that information is. If a dispute is not settled then I hope you will agree to attempt to resolve it by engaging in good faith with me in a process of mediation or arbitration. If you are in any way dissatisfied about how I process your personal information, you have a right to lodge a complaint with the Information Regulator. However, I would appreciate that if you have a concern, you raise it with me and allow me to resolve it before complaining to the Regulator.

Retention period for personal information

Except as otherwise mentioned in this privacy notice, I keep your personal information only for as long as required by me:

  • to provide you with the services you have requested
  • to comply with other law, including for the period demanded by tax authorities
  • to support a claim or defence in court

Compliance with the law

This privacy policy complies with the Protection of Personal Information Act 2013 (‘POPIA’).

Review of this privacy policy

I may update this privacy notice from time to time as necessary.