Project Sophia Ltd
- We take your privacy extremely seriously, and we never sell lists or email addresses
- We will always give you the opportunity to unsubscribe from our services and ensure you can unsurescribe without difficulty
- We will not send excessive numbers of emails; when we do send emails we will always try to ensure they are informative, useful and targeted
- We will only ask you for the minimum amount of information necessary to provide you with the products, services or communications you have requested
- We will do our utmost to protect your personal information from theft, fraud, other malicious activity and technical failures
|Data||collectively all information that you submit to Project Sophia Ltd via our Websites. This definition incorporates, where applicable, the definitions provided in the Data Protection Act 1998;|
|Cookies||a small text file placed on your computer by a Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);|
|Project Sophia Ltd, or us, or we, or PSL||Project Sophia Ltd, a company incorporated in England and Wales with registered number 08140280 whose registered office is at Cleveland Way, Helmsley, North Yorkshire, YO62 5AT;|
|UK and EU Cookie Law||the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;|
|User or you||any third party that accesses our Websites and is not either (i) employed by Project Sophia Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Project Sophia Ltd and accessing our Websites in connection with the provision of such services; and|
|Website(s)||any of our Websites which use the following domains (or their sub-domains): projectsophialtd.co.uk, living-money.com, jeremy.deedes.com, unless expressly excluded by their own terms and conditions. For the purposes of this Statement, the URL https://www.coach.me/jeremydeedes?ref=NOjNE and any URL commencing with this URL is deemed to be included in this definition.|
|In-person client||a client with whom PSL has a close personal relationship, and works with on a one-to-one basis rather than within a group, holding meetings in person or via any form of digital communication, including WhatsApp, email and Zoom.|
|Digital client||a client with whom PSL works with as part of a group and without a one-to-one close personal connection.|
- the singular includes the plural and vice versa;
- a reference to a person includes firms, companies, government entities, trusts and partnerships;
- “including” is understood to mean “including without limitation”;
- reference to any statutory provision includes any modification or amendment of it;
- Except as set out in paragraph 5 below, we will collect from you only the minimum personal data necessary to provide the product, service or communication requested by you, which may include some or all of the following:
- Date of Birth;
- Job Title;
- Contact Information such as email addresses and telephone numbers;
- Demographic information such as post code, preferences and interests;
- Financial information such as credit / debit card numbers;
- IP address (automatically collected);
- In certain circumstances you may wish to provide more information in order to participate fully in the Living Money community or to participate in our coaching services without hindrance. This data my include special category data such as information about your race, ethnicity, health, sexuality, politics and religion.
- Living Money community members will be required to provide consent to this by confirming they have read and agreed to our specific community terms and conditions and coaching clients of Living Money will be asked to provide consent to us processing special category data through our signed coaching contract.
- We will collect your data in any or all of the following ways:
- Through your completion of forms on our Websites
- Through your completion of hard copy questionnaires
- Through the completion of questions in our Planning Projector app
- Through interviews
Our use of Data
- For purposes of the Data Protection Act 1998, Project Sophia Ltd is the ‘data controller’.
- We will retain any Data you submit for as long as necessary to provide the product, service or communication requested by you. However, if you remain inactive for a period of 12 months or more we will seek your permission to delate your personal Data.
- Unless we are obliged or permitted by law to do so, and subject to any third party disclosures specifically set out in this policy, your Data will not be disclosed to third parties. This does not include our affiliates and / or other companies within our group.
- All personal Data is stored securely in accordance with the principles of the Data Protection Act 1998. For more details on security see the clause below (Security).Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
- internal record keeping;
- transmission by email of promotional materials that may be of interest to you;
- The provision of coaching, planning and consultancy services (including the operation of our lifetime cash flow planning app);
Our processing of your data
- We will process your data under any or all of the following legal bases:
- Consent. This will be the lawful basis for processing the large majority of our data, such as mailing list data (through opt-ins) and data relating to the sale and delivery of our services.
- Contract. This will be the lawful basis for processing data relaying to our personal coaching services
- Special category data. There will be occasions when we will need to discuss ‘special category data’, such as race, politics, religion, health, sex life and sexual orientation with you in order to work with you without hindrance in developing and executing plans for your life and money, and therefore this will be a lawful basis for processing special category data. This may apply to the Living Money online community also.
- Our condition for processing special category data is that you give explicit consent to the processing of your personal data for the specific purpose of providing life coaching and financial planning services.
- For our in-person clients, consent will come in the form of a signed contract (to be revised and updated)
- For our LM Community clients this must be included in the Community T&Cs. This condition therefore requires that we include on the members website a facility for clients to tick to confirm they have read and accepted our T&Cs.
Third party websites and services
- Project Sophia Ltd may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of our Websites. The providers of such services have access to certain personal Data provided by Users of our Websites.
Links to other websites
Changes of business ownership and control
- We may also disclose Data to a prospective purchaser of our business or any part of it.
- In the above instances, we will take steps with the aim of ensuring your privacy is protected.
Controlling use of your Data
- Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:
- use of Data for direct marketing purposes; and
- sharing Data with third parties.
Functionality of the Website
- To use all features and functions available on our Websites, you may be required to submit certain Data.
Accessing and deleting your own Data
- You have the right to ask for a copy of any of your personal Data held by Project Sophia Ltd (where such Data is held) on payment of a small fee, which will not exceed £10.00. You also have the right to ask that all your data be deleted. To do so, please send an email to [email protected]
- Data security is of great importance to Project Sophia Ltd and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via our Websites.
- If password access is required for certain parts of our Websites, you are responsible for keeping this password confidential.
- We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to our Websites.
- All Cookies used by our Websites are used in accordance with current UK and EU Cookie Law.
- Before our Websites place Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Project Sophia Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
- Our Websites may place the following Cookies:
|Type of cookie||Purpose|
|Strictly necessary cookies||These are cookies that are required for the operation of our Websites. They include, for example, cookies that enable you to log into secure areas of our Websites, use a shopping cart or make use of e-billing services.|
|Analytical/performance cookies||They allow us to recognise and count the number of visitors and to see how visitors move around our Websites when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily|
|Functionality cookies||These are used to recognise you when you return to our Websites. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).|
- You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
- You can choose to delete Cookies at any time; however you may lose any information that enables you to access our Websites more quickly and efficiently including, but not limited to, personalisation settings.
- It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
Transfers outside the European Economic Area
- Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. These countries may not have data protection laws equivalent to those in force in the EEA.
- For purposes of the Data Protection Act 1998, Project Sophia Ltd is the ‘data controller’. The data controller’s representative at Project Sophia Ltd is Jeremy Deedes.
- Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
- This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
- You may contact Project Sophia Ltd by email at [email protected]
Date: 1 January 2021