PRIVACY AND COOKIE POLICY

Who We Are

Our company name is Babysteps Publishing Limited, registered in England and Wales under company number 08850109, whose registered address is at Dol Elian, Old Colwyn, Clwyd, Wales LL29 8YZ. If you wish to speak to someone about the policy, please contact us on kevin@babystepspublishing.com

We respect your right to privacy and will only process personal information about you in accordance with applicable data protection laws. We comply with General Data Protection Regulation (2016/679) and the UK Data Protection Act 2018 (the “Data Protection Legislation”). If any of these laws are replaced or superseded, we will also comply with that.

What we may collect

Personal data, or personal information, is any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you when you use our Website or use our Services. Whenever we collect personal data about you, we must have a legal ground to do so.

When you sign up to our training programme, we may ask you to provide your name, email address, telephone number, Skype username, Zoom username (or any other username for online conferencing platforms).

We use this information to allow you to participate in basic elements of the training programme, including but not limited to:

• Attending our coaching calls
• Enabling us to contact you throughout the training programme to ensure you are participating to the fullest extent, to allow you to make the most out of the programme

We will also collect information on ‘goals sheets’, which includes information on your current and future goals, and other documents you may choose to upload to our Website. We use this information to keep you accountable throughout the programme.

The legal basis for us collecting this information is performing a contract with you – this information allows us to deliver what we have agreed to in our contract to provide you with the training programme, and allows you to make the most of the programme. If you contact a member of our team to discuss customer service matters, we will use your name and email address when we interact with you. The legal basis we have for this is to provide you with assistance regarding customer service matters.

We will also use your name and email address to send you information about your account (including changes to this policy or security information). Our legal basis for using your name and email address in this way is to provide you with relevant information relating to the security of your online account, and also to ensure you have up-to-date information on how we handle your personal data.

We may ask you whether you want to opt-in to our marketing information. If you say yes to this, we will use your email address to provide you with marketing information about our products and services. Our legal basis for this is that you have provided your consent. You can withdraw your consent at any time by contacting us at kevin@babystepspublishing.com

We do not hold bank details or other financial information about you. When you sign up to our programme, we will direct you to our third party payment provider, Stripe. When you make payment through Stripe, Stripe’s privacy policy shall apply to your personal data.

When you interact with the Website

When you use our Website, we may collect some technical information about your equipment, browsing behaviour and patterns. We may collect this information by cookies, server logs and other similar technologies. We use this information to improve our Website and ensure you have a good experience on our Website. Our legal basis for this is legitimate interest to provide a high quality experience to our visitors and customers.

Information on cookies

We use cookies in accordance with the Privacy and Electronic Communications Regulations (implementing the EU Directive 2002/58/EC). Cookies are small text files placed on your device when you visit our site and are used to make the users experience more efficient. We are able to store cookies on your computer where they are necessary for the operation of the site however, for non-essential cookies we need your permission.

We use cookies to distinguish users and to improve our Website. We analyse how you use our Website, and we look at aggregate statistics about your usage, and how others use our Website. We collect certain information from these cookies, and this includes information about your IP address, your location when you access the Website, the date and time you access the Website, the language you use and the type of browser you use.

We do not track individual users or use cookies to identify individuals. We use cookies to recognise you and your preferences, improve our site's performance and collect analytical information for ourselves and our business partners. Without the knowledge gained we would not be able to provide the service we do.

These are the types of cookies we use.

• 'Session cookies' allow us to track your actions during a single browsing session, but they do not remain on your device afterwards
• 'Persistent cookies' remain on your device between sessions. We use them to authenticate you and to remember your preferences. We can also use them to balance the load on our servers and improve your experience on our Website

Session and persistent cookies can be either first or third party cookies. A first-party cookie is set by the website being visited; a third-party cookie is set by a different website. Both types of cookie may be used by us or our business partners.

The third party cookies we use are:

• Google Analytics – this is a web analytics service provided by Google, Inc. The cookies used by Google Analytics help us to analyse how users use our Website and to count the number of people who use it. Google Analytics stores your IP address anonymously. Google does not associate your IP address with any personally identifiable information
• Facebook Ads (the Facebook pixel) – these cookies collect information about how visitors use our Website. This data is collected anonymously and is used to help improve our Website’s functionality
• Google Ad Words – these cookies collect information about how visitors use our Website. This data is collected anonymously, to help make our marketing communications more relevant, and is used to improve our Website’s functionality

All our cookies are categorised by the role they fulfil on our Website:

• a. Strictly Necessary: these are essential to enable you to move around our Website and use features such as secure services. Without these cookies such services could not be provided;
• b. Functionality: allow the Website to remember your choices and to personal certain features. These cookies may be anonymised and cannot track your browsing activity on other websites; and
• c. Performance: collect information as to how users use the Website. These cookies don't collect information that identifies a visitor. The information collected is aggregated and used to improve our Website.
• d. None of the cookies employed are classified as Behavioural Targeting.

We will always ask for your consent to use non-essential cookies. You are free to withhold consent to this, but it means that we might not be able to provide the full Website experience to you, including some elements of video advertising.

If at any time you wish to disable our cookies, you may do so through the settings on your browser, or whenever the pop-up appears on our Website (each time you access the Website).

How we store your personal data

We store all your personal data on our servers within the United Kingdom.

We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfil your order and to receive our services and deal with payment. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA.

This means that sometimes we may need to use legally binding contractual terms between us and any third parties we engage with and the use of the EU-approved Model Contractual Arrangements.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see the European Commission: EU-US Privacy Shield.

Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We will still be responsible for protection of your personal data, even where we have transferred it outside the EEA.

We regularly review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.

How we disclose your information

We may disclose your information in the following cases:

• If we want to sell our business, or our company, we can disclose it to the potential buyer
• We can disclose it to other businesses in our group, as defined in the Companies Act 2006
• We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety or rights
• We can exchange information with others to protect against fraud or credit risks

We may contract with third parties/subcontractors to supply services to you on our behalf. These include cloud services used to send emails and technology providers that assist in providing services to you.

Your rights

When you provide us with personal data, you have certain legal rights, and these include:

• To request access to, deletion of or correction of, your personal data held by us at no cost to you
• To request that your personal data be transferred to another person (data portability)
• To be informed of what data processing is taking place
• To restrict processing
• To object to processing of your personal data
• To complain to a supervisory authority

If you wish to access, rectify, erase or transfer your personal data, please contact us at kevin@babystepspublishing.com

What happens when we link to other websites

This privacy policy only relates to our Website and our Services. We might have links on our Website to other websites, and these websites will have their own terms and conditions and privacy policies. You should check those privacy policies before providing your personal data to those websites.

Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our Website. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

Notice for California residents of privacy practices and rights

If you are a California resident, California law may provide you with additional rights regarding your personal data.

Your rights

The California Consumer Privacy Act of 2020 (“CCPA”) gives you the following rights.

• Right to know about the personal information we collect and share
• The CCPA gives you the right to request that we disclose the specific pieces of personal information we have collected about you
• Please see above for information on the data we collect on you, and how we process it
• We do not sell your personal information. However, we do disclose your personal data to limited third parties, as described above

Right of deletion

• You have the right to request that we delete your personal information, subject to certain exceptions
• If you wish to delete your personal data, please contact us at kevin@babystepspublishing.com. Please note that we may require certain information from you in order to verify your identity before proceeding with your request

Disclosures about your personal information

We collect the categories of personal information from you in connection with your use of our Website as described above.

Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights.

The changes we may make to this policy

We can update this policy from time to time as laws change or as our Services or Website change. If we make material changes to the policy, and we need your consent to those changes, we will contact you by email to do so.