
Privacy Notice
SEABURY PERFORMANCE PRIVACY NOTICE
1. About This Privacy Notice
Seabury Performance respects your privacy and is committed to handling personal information responsibly and in accordance with applicable UK data-protection law, including the UK General Data Protection Regulation and Data Protection Act 2018.
This Privacy Notice explains how we collect, use, store and share personal information when you:
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visit our Website;
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contact us;
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submit an enquiry;
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subscribe to communications;
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interact with our online content; or
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otherwise provide personal information to Seabury Performance.
Separate or additional privacy information may be provided in connection with particular professional services, research activities or other engagements where appropriate.
2. Who We Are
For the purposes of applicable data-protection law, the controller responsible for the personal information described in this Notice is:
Seabury Performance
Website: seaburyperformance.com
3. Personal Information We May Collect
Depending upon how you interact with us, we may collect:
Identity and contact information, including your name, email address, telephone number, organisation, job title or other information you choose to provide.
Enquiry and communication information, including messages, correspondence, enquiry details and records of communications with us.
Professional information, where you provide information about your role, organisation, team, programme, project or professional requirements in connection with an enquiry.
Newsletter and marketing information, including subscription status, communication preferences and interactions with communications where relevant.
Technical and usage information, which may include IP address, browser or device information, Website interactions, pages visited, referral information and other technical information generated when using the Website.
Cookie and storage/access information, as described in our Cookie Notice.
Other information you voluntarily provide when communicating with Seabury Performance.
4. Special Category and Sensitive Information
Our public Website is not intended as a general channel for submitting confidential medical or highly sensitive personal information.
Because Seabury Performance works within psychology and performance, some professional engagements may legitimately involve health, psychological or other special-category information.
Where this occurs, such information will be handled under the appropriate lawful basis and additional condition required by data-protection law, and may be subject to separate privacy, consent or professional arrangements.
Please avoid sending unnecessary sensitive personal information through general Website enquiry forms.
5. How We Obtain Personal Information
We may obtain information:
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directly from you when you contact us or complete a form;
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when you subscribe to communications;
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through your interactions with our Website;
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from organisations or representatives contacting us on your behalf;
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from publicly available professional sources where appropriate; or
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through service providers supporting Website operation, communications, security or analytics.
Where we obtain personal information from another source, we will provide privacy information where required by law.
6. Why We Use Personal Information and Our Lawful Bases
We only process personal information where we have an appropriate lawful basis.
Responding to enquiries
We use information to respond to questions, discuss potential work and communicate with prospective clients, partners or other contacts.
Our lawful basis will normally be legitimate interests in operating our business and responding to enquiries, or taking steps at your request before entering into a contract.
Providing professional services
Where you become a client or engage Seabury Performance, information may be processed to establish, administer and deliver the relevant engagement.
The lawful basis may include contract, legitimate interests and, where appropriate, legal obligations.
Additional arrangements may apply where special-category information is involved.
Operating and protecting the Website
We may process technical information to operate, maintain and protect our Website, prevent abuse, investigate security incidents and maintain service integrity.
Our lawful basis will normally be legitimate interests in maintaining a secure and effective Website and, where relevant, compliance with legal obligations.
Website analytics and improvement
We may use information to understand how the Website is used and improve its content and performance.
Depending upon the technology involved, processing may rely on consent or legitimate interests, and applicable PECR requirements and exceptions will also be considered.
Marketing and newsletters
Where appropriate, we may send newsletters, Insights or other marketing communications.
Where consent is required, we will rely upon consent.
In circumstances where applicable law permits another basis, we may rely upon that basis provided all relevant requirements are met.
You can unsubscribe from marketing communications at any time.
Legal, regulatory and professional obligations
We may process information where necessary to comply with applicable legal, regulatory, insurance, professional or safeguarding obligations.
The lawful basis may include legal obligation or legitimate interests, depending upon the circumstances.
Establishing or defending legal rights
We may process relevant information where reasonably necessary to establish, exercise or defend legal claims or protect our rights.
Our lawful basis will normally be legitimate interests, subject to applicable legal requirements.
7. Legitimate Interests
Where we rely on legitimate interests, those interests may include:
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operating and developing Seabury Performance;
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responding to legitimate enquiries;
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managing professional relationships;
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maintaining Website and information security;
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preventing misuse or fraud;
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understanding and improving our services;
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maintaining appropriate business records; and
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establishing, exercising or defending legal rights.
We consider whether our interests are overridden by the rights and interests of the individuals concerned before relying upon this basis.
8. Who We May Share Information With
We do not sell personal information.
Where necessary and appropriate, information may be processed by or shared with:
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Website hosting and technology providers;
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Wix and services used to operate the Website;
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email and communications providers;
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analytics providers;
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professional advisers such as accountants, insurers, solicitors or data-protection advisers;
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contractors or associates supporting Seabury Performance where appropriate and subject to suitable obligations;
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regulators, courts, law-enforcement bodies or other authorities where legally required; or
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another party where you have requested or authorised the disclosure.
Service providers may process personal information on our behalf only for appropriate purposes and subject to applicable contractual and legal protections.
9. Third-Party Retailers
Our Products pages may link to third-party retailers such as Amazon.
Seabury Performance does not normally receive the personal information you provide directly to a third-party retailer merely because you followed a link from our Website.
Those organisations act according to their own privacy notices and data practices.
You should review their privacy information before providing personal data.
10. International Transfers
Some technology or service providers may process personal information outside the United Kingdom.
Where personal information is transferred internationally, we will take appropriate steps where required to ensure that the transfer complies with applicable UK data-protection law.
These safeguards may include applicable adequacy regulations, recognised contractual safeguards or another lawful transfer mechanism.
11. How Long We Keep Personal Information
We keep personal information only for as long as reasonably necessary for the purpose for which it was collected and to satisfy applicable legal, regulatory, professional, insurance, accounting or reporting requirements.
Retention periods vary according to the nature and context of the information.
As a general approach:
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unsuccessful or general enquiries will normally be retained only for as long as reasonably necessary for follow-up and business records;
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client and contractual records may be retained for longer where necessary for legal, professional, insurance or accounting purposes;
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marketing information may be retained until you unsubscribe or until it is no longer reasonably required;
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technical and security information may be retained for an appropriate period for security, investigation and Website operation; and
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information connected with legal claims may be retained for as long as reasonably necessary in relation to those claims.
Information will then be deleted, anonymised or otherwise securely disposed of where appropriate.
12. Security
We take reasonable and appropriate technical and organisational measures to protect personal information from accidental or unlawful loss, misuse, alteration, unauthorised access or disclosure.
However, no Internet-based system can be guaranteed to be completely secure.
13. Your Data-Protection Rights
Depending upon the circumstances and lawful basis involved, you may have rights including:
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the right to be informed about how your information is used;
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the right to request access to personal information we hold about you;
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the right to request correction of inaccurate or incomplete information;
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the right to request erasure in certain circumstances;
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the right to request restriction of processing in certain circumstances;
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the right to object to certain processing;
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the right to data portability where applicable;
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rights concerning certain automated decision-making; and
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the right to withdraw consent at any time where processing is based upon consent.
These rights are not absolute and may be subject to legal exemptions or limitations.
We may need to verify your identity before responding to certain requests.
The ICO confirms that the precise rights available depend partly on the lawful basis being used.
14. Automated Decision-Making
Seabury Performance does not currently use personal information collected through the public Website to make solely automated decisions producing legal or similarly significant effects on individuals.
If this changes, this Notice will be updated and appropriate information will be provided.
15. Marketing Preferences
You may unsubscribe from marketing emails using the unsubscribe option provided in the communication or by contacting us.
Withdrawing marketing consent does not affect the lawfulness of processing carried out before withdrawal and does not necessarily affect non-marketing communications that we have another lawful reason to send.
16. Cookies and Similar Technologies
Our Website may use cookies and other storage and access technologies.
Please see our Cookie Notice for information about these technologies, their purposes and your choices.
17. Links to Other Websites
Our Website may link to independent third-party websites.
This Privacy Notice applies to Seabury Performance and does not govern the independent processing activities of third parties.
We recommend reviewing the privacy information provided by any external website you visit.
18. Children's Information
The public Website is not designed for children to provide personal information independently through general Website forms.
Seabury Performance's professional work may involve junior athletes or other young people. Where we provide services involving children, appropriate arrangements concerning consent, safeguarding, confidentiality and data protection will be applied separately according to the nature of the engagement.
19. Complaints
If you have concerns about how Seabury Performance has handled your personal information, please contact us first so that we have an opportunity to address the issue.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent data-protection regulator.
Information Commissioner's Office
The ICO expects privacy notices to explain that individuals can complain to it.
20. Changes to This Privacy Notice
We may update this Notice where our practices, services, technologies or legal obligations change.
The latest version will be published on this Website with its revision date.
21. Contact
For privacy questions or requests:
Seabury Performance
Website: seaburyperformance.com/contact