I take your privacy very seriously. Please read this privacy policy carefully as it contains important information about who I am and how and why I collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact me or supervisory authorities in the event you have a complaint.

This privacy policy is divided into the following sections:

1. Who I am
2. My collection and use of your personal data
3. Who I share your personal data with
4. Cookies and other tracking technologies 
5. How to manage cookies
6. Marketing
7. Your rights
8. How long your personal data will be kept
9. Keeping your personal data secure
10. How to complain
11. How to contact me 
12. Changes to this privacy policy
13. Privacy policies of other websites
14. CCPA privacy information

My name is Genevieve Wastie and I am currently operating as a sole trader in Portugal under my married name, Genevieve Nathwani (“I”, “me”, “my”). 

I collect, use and am responsible for certain personal data about you. When I do so I am subject to EU General Data Protection Regulation (EU GDPR). 

Please see ‘How to contact me’ at the end of this policy if you have any questions about this privacy policy or the data I hold about you.

How your personal data is collected

I may collect personal data about you when you access my website, contact me directly, complete a discovery questionnaire, engage with me during our coaching sessions, sign up to my newsletter or when your employer registers you for one of my services. 

I collect this personal data from you either directly, such as when you contact me or interact with me during coaching sessions or indirectly, from your employer or by monitoring your browsing activity while you are using my website (see “Cookies” below).

I also collect personal data about you from other sources as follows:

• from third parties such as the third party cookie providers listed in my Cookie Notice and
• From publicly available sources such as Companies House, LinkedIn and other organisation websites.

Personal data I collect about you

The personal data I collect about you depends on the purpose for which you engage with me. I may collect and use the following data about you: 

• Identity Data - full name, date of birth, passport/national ID information and gender.
• Contact Data - address, email address and telephone number(s).
• Financial Data - bank account and payment card details.
• Transaction Data - data relating to the purchase of services by you.
• Technical Data - internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Usage Data - data about how you use my website and services.
• Marketing and Communications Data - your preferences in receiving marketing from me and your communication preferences.
• Coaching services data - why you sought coaching, your goals for coaching, my observations from our coaching sessions.

This personal data is required to provide my services. If you do not provide personal data I ask for, it may delay or prevent me from providing services to you or your employer. 

This website is not intended for use by children and I do not knowingly collect or use personal data relating to children under the age of 13.

Special category data

I may collect information about your racial or ethnic origin for diversity monitoring and reporting purposes but will only do so where I have your explicit consent.

Apart from this, I do not request that you provide me with any special category personal data, for example personal data which is more sensitive such as data about your health or disabilities, however I acknowledge that you may provide this information during the course of a coaching session with me.

Where I process special category personal data, I will ensure I am permitted to do so under data protection laws, for example:

• I have your explicit consent;
• the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
• the processing is necessary to establish, exercise or defend legal claims.

How and why I use your personal data

Under data protection law, I can only use your personal data if I have a lawful basis for doing so, for example:

• Consent: where you have given me clear consent for me to process your personal data for a specific purpose;
• Contract: where my use of your personal data is necessary for a contract I have with you, or because you have asked me to take specific steps before entering into a contract;
• Legal obligation: where my use of your personal data is necessary for me to comply with the law (not including contractual obligations); or

Legitimate interests: where my use of your personal data is necessary for my legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal data which overrides my legitimate interests).

My name is Genevieve Wastie and I am currently operating as a sole trader in Portugal under my married name, Genevieve Nathwani (“I”, “me”, “my”). 

I collect, use and am responsible for certain personal data about you. When I do so I am subject to EU General Data Protection Regulation (EU GDPR). 

Please see ‘How to contact me’ at the end of this policy if you have any questions about this privacy policy or the data I hold about you.

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use my website. I use cookies on my website. Cookies help me recognise you and your device and store some data about your preferences or past actions.

For further information about cookies please click the MANAGE YOUR COOKIES link in the footer.

You can set your browser not to accept cookies. However, in a few cases, some of my website features may not function as a result.

I may use your personal data to send you updates (by email, text message, telephone or post) about my services, including exclusive offers, promotions or new services. Where I have your consent or it is in my legitimate interests to do so, I may do this by post, email, or text message.

If you have given your consent to receive marketing communications, or it is in my legitimate interests to send them (for example because you have previously used my services or are a business user) you always have the right to opt out of receiving further promotional communications by:

• contacting me at genevieve@genevievenathwani.com or;
• using the ‘unsubscribe’ link in emails

I may ask you to confirm or update your marketing preferences if there are changes in the law, regulation, or the structure of my business.

Please note that I may also send you other communications in relation to your use of my services or in order to respond to queries you have raised, such communications are service communications and are not a form of marketing.

You have the following rights, which you can exercise free of charge:

• Access: The right to be provided with a copy of your personal data (the right of access)
• Rectification: The right to require me to correct any mistakes in your personal data
• To be forgotten: The right to require me to delete your personal data—in certain situations
• Restriction of processing: The right to require me to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
• Data portability: The right to receive the personal data you provided to me, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations
• The right to object:

• At any time to your personal data being processed for direct marketing (including profiling);
• in certain other situations to my continued processing of your personal data, e.g. processing carried out for the purpose of my legitimate interests.

• Not to be subject to automated individual decision making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information about your rights please contact me or see the guidance provided by the EU Information Commissioner’s Office (ICO) on individuals’ rights.

If you would like to exercise any of your rights, please:

• see the 'How to contact me section at the end of this policy; 
• let me have enough information to identify you e.g. your full name, address and your employer/company name);
• let me have proof of your identity (a copy of your driving licence or passport); and
• let me know which right you want to exercise and the data to which your request relates.

I will not retain your personal data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal data. 

When it is no longer necessary to retain your personal data, I will delete or anonymise it.

As an indication, if you or your employer purchase services from me, I will keep your personal data while I am providing such services. Thereafter, I will keep your personal data for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that I treated you fairly; and
• to keep records required by law.

I have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. I limit access to your personal data to those who have a genuine business need to access it. Those processing your data will do so only in an authorised manner and are subject to a duty of confidentiality. 

I also have procedures in place to deal with any suspected data security breach. I will notify you and any applicable regulator of a suspected data security breach where I am legally required to do so.

Please contact me if you have any query or concern about my use of your data (see below ‘How to contact me’). I hope I will be able to resolve any issues you may have.

If you are based in the EU, you have the right to lodge a complaint with the European Data Protection Supervisor. Please find relevant contact information for member states here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

You can contact me by email at genevieve@genevievenathwani.com if you have any questions about this privacy policy or the data I hold about you, to exercise a right under data protection law or to make a complaint.

This privacy policy was last updated in September 2022. I keep my privacy policy under regular review to make sure it is up to date and accurate. If I change my privacy policy from time to time, I will post the details of any changes here. I may also take reasonable steps to notify you if such changes affect how your personal data is processed.

My website may contain links to other websites. My privacy policy applies only to my website, so if you click on a link to another website, you should read their privacy policy.

This section for California residents supplements the information contained in this privacy policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to us.

Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

Collected: Yes

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No.

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: No.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Under CCPA, personal information does not include:

• Publicly available information from government records
• Deidentified or aggregated consumer information
• Information excluded from the CCPA's scope, such as:

• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
• Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from the forms you complete on our website, preferences you express or provide through our website, or from your purchases on our website.
• Indirectly from you. For example, from observing your activity on our website.
• Automatically from you. For example, through cookies we or our service providers set on your device as you navigate through our website.
• From service providers. For example, third-party vendors to monitor and analyse the use of our website, third-party vendors to deliver targeted advertising to you, third-party vendors for payment processing, or other third-party vendors that we use to provide the website to you.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:

• To operate our website and provide you with our website.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our website.
• To fulfill or meet the reason you provided the information. For example, if You share your contact information to ask a question about our website, We will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.

If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes we will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity

Share of Personal Information

We may share your personal information identified in the above categories with the following categories of third parties:

• Service providers
• Payment processors
• Our affiliates
• Our business partners
• Third party vendors to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our website, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorised representative) may submit a request to us by contacting us.

If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:

• The right to notice. You have the right to be notified which categories of personal data are being collected and the purposes for which the personal data is being used.
• The right to request. Under CCPA, You have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of personal information. Once we receive and confirm your request, we will disclose to you:

• The categories of personal information we collected about you
• The categories of sources for the personal information we collected about you
• Our business or commercial purpose for collecting or selling that personal information
• The categories of third parties with whom we share that personal information
• The specific pieces of personal information we collected about you
• If we sold your personal information or disclosed your personal information for a business purpose, we will disclose to you:

• The categories of personal information categories sold
• The categories of personal information categories disclosed

• The right to say no to the sale of personal data (opt-out). You have the right to direct us to not sell your personal information. To submit an opt-out request please contact us.
• The right to delete personal data. You have the right to request the deletion of your personal data, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete) Your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer's rights, including by:

• Denying goods or services to you
• Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
• Providing a different level or quality of goods or services to you
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact us:

By email: genevieve@genevievenathwani.com 

Only you, or a person registered with the California Secretary of State that you authorise to act on your behalf, may make a verifiable request related to your personal information.

Your request to us must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorised representative
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it

We cannot respond to your request or provide you with the required information if we cannot:

• Verify your identity or authority to make the request
• And confirm that the personal information relates to you

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance

Do Not Sell My Personal Information

You have the right to opt-out of the sale of your personal information. Once we receive and confirm a verifiable consumer request from you, we will stop selling your personal information. To exercise your right to opt-out, please contact us.

The service providers we partner with (for example, our analytics or advertising partners) may use technology on the website that sells personal information as defined by the CCPA law. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.

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