Privacy Policy

1.About this policy

Draft for publication. Items marked [CONFIRM] must be settled and the markers removed before this policy goes live.

This policy explains how Coach Falco collects, uses and protects your personal information when you enquire, book coaching, send us videos, take part in our activities or use www.coach-falco.com.

Coach Falco is the trading name of Falco Niekoop-Bird, a sole trader in England. Falco is the data controller, which means he decides how and why your information is used and is responsible for protecting it.

Contact for privacy matters:

• Email: coach.falco.sports@gmail.com
• Alternative email: niekoop.falco@gmail.com

The Newbury Tennis Club address is used for correspondence only. The club does not own or operate Coach Falco and is not responsible for how Coach Falco uses your information.

ICO registration number: [CONFIRM: number once the data protection fee is paid]

This policy sits alongside our Terms of Business.

2.The information we collect

We only collect what we need to coach you well, keep you safe and run the business. Depending on how you deal with us, this may include:

• Contact and identity details: name, email address, phone number, postal address and date of birth or age group
• Booking and payment details: the services you book, dates, venues, prices, invoices and payment records (we do not store full card details)
• Coaching records: your playing level, goals, session notes, progress assessments and training plans
• Health information: medical conditions, injuries, disabilities or other health matters you tell us about so that we can coach you safely
• Junior information: a child's details, plus parent or guardian contact details, emergency contacts, collection arrangements and any needs affecting the child's safety
• Videos and written submissions: tennis footage and written questions you send for virtual coaching or written advice, and our annotated feedback
• Photos, film and audio: images and recordings taken at sessions, events or Talking Tennis interviews
• Marketing preferences: whether you have agreed to hear from us, and your choices about promotional photography
• Correspondence: emails, messages and website form submissions
• Website information: technical data such as your device, browser and pages visited, collected through cookies and similar technologies (see section 9)

Most of this information comes directly from you. Some may come from a parent or guardian, or from a club or venue where you have asked to be referred to us.

3.How we use your information and our lawful bases

Data protection law requires us to have a lawful basis for each use of your information. Ours are:

Where we rely on legitimate interests, we have balanced our interests against yours, and you can object (see section 14).

We do not sell your information, and we do not make decisions about you using solely automated processing.

4.Health information

Health information is "special category" data, so it receives extra protection.

We ask about health matters, such as heart conditions, high blood pressure, previous strokes, injuries or medical advice limiting exercise, only so that we can coach you safely and adapt activities where needed.

• Lawful basis: your explicit consent (Article 9(2)(a) UK GDPR), given when you share the information with us. In an emergency where you cannot give consent, we may share relevant health information with emergency services to protect your life (Article 9(2)(c)). Where an incident or injury occurs, we may keep relevant records to establish or defend legal claims (Article 9(2)(f)).
• Who sees it: only Falco, and anyone else who needs it to keep you safe, such as emergency services or, where necessary, a supervising coach at an activity.
• What we never do: use health information for marketing or share it with clubs, partners or sponsors for their own purposes.
• Withdrawing consent: you can withdraw consent at any time. If you do, we may not be able to provide some activities safely, and we will explain this to you.

[CONFIRM: how health information is stored and protected, for example an encrypted account with restricted access. Health declarations must not be collected through the website until this is in place.]

5.Children and safeguarding

We coach children only with the authorisation of a parent or legal guardian, who usually provides the child's information on their behalf.

We use children's information to deliver coaching, keep them safe, contact parents or guardians and manage arrival and collection.

If we have a safeguarding concern about a child or vulnerable adult, we may share relevant information with the appropriate authorities, such as the LTA safeguarding team, local authority children's services or the police. We do this where the law requires or permits it to protect someone from harm, including under the safeguarding condition in the Data Protection Act 2018. We may do so without consent where asking for consent would put someone at risk.

[CONFIRM: safeguarding contact details and the written policy that supports this processing.]

Children's information is never used for marketing. Children can ask about their own information, and we will respond in a way suited to their age and understanding.

6.Virtual coaching videos and written submissions

When you send us tennis footage or written questions, we use them only to provide the coaching service you have asked for (lawful basis: performing our contract).

• Private coaching footage is kept confidential and is not used in public or promotional content without your separate permission.
• Please send only footage you are entitled to share. If other people can be identified in it, make sure they are happy for it to be shared, or crop or blur them where possible.
• You keep your rights in your original recordings.

[CONFIRM: where footage and submissions are stored, how they are sent to us securely, and how long they are kept.]

7.Photography, filming and audio

We may take photos, video or audio at sessions, events and Talking Tennis interviews.

Promotional use of identifiable images is optional. We will ask for your separate consent (or a parent's or guardian's consent for children) before using identifiable images or recordings on our website, social media, advertising or brand collaborations. Saying no will not affect your coaching.

You can withdraw consent or ask us to review, remove or obscure an image at any time by emailing us. We will remove it from channels we control as quickly as we reasonably can. Printed materials already distributed, and copies shared independently by others, may not be fully retrievable.

Talking Tennis guests will be told how their contributions will be used before recording.

8.Marketing communications

We will only send you marketing emails or messages if:

• you have agreed to receive them; or
• you are an existing client and the messages are about similar Coach Falco services. You can opt out when your details are collected and in every message (the "soft opt-in").

You can unsubscribe at any time using the link in our emails or by contacting us. We will never share your details with others for their marketing.

9.Cookies, website forms and email

Our website uses cookies and similar technologies.

• Essential cookies make the site work and keep it secure. They do not need consent.
• Analytics cookies help us understand how the site is used so we can improve it. Where the law allows, we may use these without asking first, but we will tell you about them and give you a simple way to opt out.
• Advertising, social media and other non-essential cookies will only be used if you agree. You can change your choice at any time.

[CONFIRM: the final list of cookies and tools used on www.coach-falco.com once the site build is complete, and the cookie banner or settings link.]

When you use a website form or email us, your message is delivered to our inbox and kept with our correspondence. [CONFIRM: final form and email delivery set-up.]

10.Who we share your information with

We share information only where needed, and only as much as needed:

• Service providers who help us run the business, such as email, cloud storage, website hosting, online forms and payment providers. They act on our instructions and must protect your information. [CONFIRM: list of providers.]
• Venues and clubs where you are coaching, where they need details such as attendance or emergency contacts
• Emergency services where someone's health or safety is at risk
• Safeguarding authorities as described in section 5
• Professional advisers and insurers, such as our accountant, lawyers and insurance providers, where needed for advice, claims or compliance
• HMRC, regulators and law enforcement where the law requires it
• Partners and collaborators only where you have asked us to or agreed to it

If you book through a tennis centre, club or other organisation, that organisation is responsible for its own handling of your information under its own privacy policy.

11.International clients and transfers

We coach clients around the world. When you send us information from outside the UK, it is handled under UK data protection law.

Some of our service providers may store or process information outside the UK. Where they do, we make sure appropriate safeguards are in place, such as a UK adequacy decision or the UK's approved international data transfer contracts.

[CONFIRM: which providers transfer data outside the UK and the safeguard relied on for each.]

12.Keeping your information secure

We take appropriate technical and practical steps to protect your information from loss, misuse and unauthorised access. These include password-protected accounts, limiting access to what is needed and taking extra care with health information, children's information and private footage.

[CONFIRM: the specific security measures in place, for example two-step verification on all accounts, encrypted storage and secure device use.]

If a data breach is likely to put your rights at risk, we will report it to the Information Commissioner's Office within 72 hours where required. We will tell you directly if the risk to you is high.

13.How long we keep your information

We keep information only for as long as we need it, then delete or anonymise it securely.

14.Your rights

You have the right to:

• Access the personal information we hold about you
• Correct information that is inaccurate or incomplete
• Delete your information in certain circumstances
• Restrict how we use your information in certain circumstances
• Object to our use of your information where we rely on legitimate interests, and at any time to direct marketing
• Data portability: receive information you gave us in a usable format, or have it sent to someone else, where we rely on consent or contract
• Withdraw consent at any time where we rely on it. This does not affect anything we did before you withdrew.

To use any of these rights, email us. We may need to confirm your identity. We will respond within one month, which may be extended in limited circumstances, and there is normally no charge.

Parents and guardians can make requests on behalf of younger children. Older children who understand their rights may make requests themselves.

15.Complaints

If you are unhappy with how we have handled your information, please tell us first so that we can put it right. Email us with "Data protection complaint" in the subject line, or write to the correspondence address above. We will acknowledge your complaint within 30 days and deal with it without undue delay.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK data protection regulator:

• Website: ico.org.uk/make-a-complaint
• Helpline: 0303 123 1113
• Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

16.Changes to this policy

We will update this policy as Coach Falco grows and as new services launch. We will publish the latest version on our website and, where changes are significant, let clients know.

17.Contact us