Introduction

PRIVACY POLICY

This privacy policy sets out how Spring Back Guide Ltd uses and protects your personal data.

Important information and who we are

Controller

SPRING BACK GUIDE LTD, a company incorporated in Scotland with company number SC764237 and having its registered office address as Third Floor, 3 Hill Street, Edinburgh, United Kingdom, EH2 3JP, is the controller and responsible for your personal data (referred to as “Spring Back”, "we", "us" or "our" in this privacy policy).

We provide a digital-based coaching solution to help businesses support their employees pre-, during and post-maternity leave, in order to promote holistic, end-to-end employee engagement throughout an employee’s maternity journey. Our services are designed to provide tailored support for both the employer organisation and the women returning to work. Our digital support includes digital access to our guide materials, the creation of a tailored Returnity Plan for personalised progress tracking, one-to-one coaching sessions and regular email communications with advice and information.

If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 10).

The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes residential address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
• Profile Data includes your username and password, your interests, preferences, feedback and responses.
• Usage Data includes information about how you interact with and use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Health information includes information you may choose to share with us concerning your physical and/or mental health and wellbeing during one-to-one coaching sessions or when using some of our other services, such as creating a Digital Returnity Plan.
• Financial information includes information you may choose to share with us concerning your financial position during one-to-one coaching sessions or when using some of our other services, such as creating a Digital Returnity Plan.
• Relationship information includes information you may choose to share with us concerning your home/family life during one-to-one coaching sessions or when using some of our other services, such as creating a Digital Returnity Plan.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

We may also share some aggregated data, such as statistical data, with your employer. This will not directly (or indirectly) reveal your identity. It will be used to provide feedback to the employer on the use of our services, for example, by providing numbers of users. We may also share some aggregated data with a view to enhancing the employee experience, for example, by sharing general themes extracted from the data with your employer.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• register on our digital platform;
• use our services and materials on our digital platform;
• engage in one to one coaching with us;
• subscribe to our service or publications;
• request marketing to be sent to you;
• participate in our one-to-one coaching sessions;
• make use of our interactive services, such as the Digital Returnity Plan; or
• give us feedback or contact us.
• Identity and Contact Data is collected from your employer.
• Automated technologies or interactions. As you interact with our digital platform, our digital platform provider (Teachery Inc.) will automatically collect Technical Data about your equipment, browsing actions and patterns. Please refer to Teachery Inc’s Privacy Policy for more information (Teachery Privacy Policy | Teachery).

If you choose to access some of our services, such as the Digital Returnity Plan, then you will be using Google Forms to enter your personal data. You will be notified of this prior to accessing these services and will be asked to provide consent to share your data with Google Forms. Using such services is optional and you can still access the other materials on the digital platform if you decide not to consent to using Google Forms. Please refer to Google Forms’ Privacy Policy for more information (Privacy Policy – Privacy & Terms – Google).  

Further information is given below about our relationship with Teacher Inc and Google Forms.

How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to enable us to give you the best and most secure customer experience, and to provide our services to you in a way which is useful and enhancing your employment journey. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• [Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.]

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

• To register you on our digital platform so you can access our products and services: your employer will share your Contact Data and Identity Data with us so that we can register you on our digital platform, to allow you to use our services and products. We will rely on the legal bases of the legitimate interest of enabling us to provide our services to you.

• To provide you with tailored products and services: some of our products and services are tailored to meet your specific needs, and so we require your personal data to give you the products and services which are most useful to you. You will provide this personal data when you interact with our digital platform. We rely on the legal bases of the legitimate interest of enhancing your use of our services and products, [and consent].

• To provide you with bespoke and tailored advice: Some of our services, such as the Digital Returnity Plan, are specifically created and tailored to each individual’s needs. We will collect your personal data using a Google Form but we will ask you to provide consent to this first. If you do not want to provide Google Form with your personal data, then you will not be able to create a Digital Returnity Plan but you will still be able to access our other products and services. We rely on the legal bases of the legitimate interest of enabling us to provide tailored and bespoke services to you, [and consent].

• To provide one-to-one coaching to you: We offer a one-to-one coaching/mentoring service which you may choose to participate in. As part of this service, you will be sharing personal information with us so that we can provide you with guidance, advice and support in helping you return to work. It is at your own discretion what information you share, but in order to get the most out of the service, it helps to be open and transparent with your coach/mentor. We rely on the legal bases of the legitimate interest of enabling us to provide tailored and bespoke services to you, [and consent].

• To provide you with ongoing support and advice via email: We will follow-up on any coaching session with an email setting out our guidance and support. You will be asked in the coaching session whether there is any information which should be excluded from the email (e.g. information which is particularly sensitive), but please be reassured that this email will only be shared with you. We will not include any information which you do not want to be written down. We rely on the legal bases of the legitimate interest of enabling us to provide tailored and bespoke services to you, [and consent].

Direct marketing

During the registration process on our digital platform when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from Spring Back Guide via [EMAIL, SMS, TELEPHONE, POST].

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view of which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Opting out of marketing

You can ask to stop sending you marketing communications at any time [by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links within any marketing communication sent to you or by contacting us [LINK]].

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes [for example relating to [order confirmations for [a product/service warranty registration, appointment reminders, updates to our Terms and Conditions, checking that your contact details are correct].

Disclosures of your personal data

We may share aggregated data which is derived from personal information with your employer, but you will not be able to be identified (directly or indirectly) from such data.

International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the safeguards described below are in place.

We currently transfer personal data to the following parties who are both based in the United States of America:

• Teachery Inc. – who provide us with the digital platform we use. When you register with our digital platform, and whenever you interact with the digital platform, Teachery Inc. will process your personal data on our behalf. This may include your Identity Data, Contact Data, Technical Data, Profile Data, Usage Data and Marketing and Communications Data.

The transfer of personal data to Teachery Inc. is permitted under the data protection legislation by virtue of Article 49(1)(c) UK GDPR – this means that the transfer of data is necessary for the performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person. In simple terms, the transfer of personal data is necessary for us to perform the Services in your interest, as agreed in the contract between us and your employer [or yourself].

• Google LLC – who, through Google Forms, helps use to deliver part of the Services. When you use our tailored services, such as creating a digital Returnity Plan, then we may ask you to complete standardised forms using Google Forms. When participating in the one-to-one coaching sessions, then we may record some of the information you provide in Google Forms. Google LLC then collects and stores this personal data for us. This may include your Identity Data, Contact Data, Technical Data, Profile Data, Usage Data, Marketing and Communications Data, Health Information, Financial Information and Relationship Information.

Google LLC is certified as complying with the EU-U.S. and Swiss-U.S. Data Privacy Frameworks (DPF) and the UK Extension to the EU-U.S. DPF. This means that it is certified to ensure a similar degree of protection afforded to your personal data.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in paragraph 4 for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• If you want us to establish the data's accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, see Contact details (paragraph 10).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

• Email address: letty@springbackguide.com
• Postal address: Spring Back Guide Ltd, 3 Hill Street, Edinburgh, United Kingdom, EH2 3JP

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

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