To provide you with our coaching, mentoring and training support services we need to collect information about you. Our aim is not to be intrusive, and we won’t ask you unnecessary questions. Any information we receive about you will be subject to strict controls to minimise the risk of misuse – including unauthorised access to, or disclosure of, your personal data.
This includes consenting to the processing of any sensitive personal information you provide, as described below in section 2. It also includes information you provide when you browse our website, request a quote, register for an account, enter into a contract for the supply of services, enter a promotion or survey and when you contact us for other reasons.
A special note about children
Children are not eligible to use New Level Results Services. We respectfully ask that minors (persons under the age of 18) do not submit any information to us or use New Level Results Services.
2. What information we collect
Information we may collect from you
We may collect and process the following information about you:
Information you provide to us
You may provide us with information by filling in forms on our website, our portals, our partners’ websites or by talking with us by over the phone or corresponding with us via email or otherwise.
This includes information you provide when you browse our website, request a quote, register for an account, enter into a contract for the supply of our services, enter a promotion or survey and when you contact us for other reasons.
To work with a New Level Results coach or use New Level Results Services, you must provide your name, and email address. When you complete any of our coaching programmes you will be asked a series of questions which detail your personal and business results and aspirations for the future. We do not collect any identity document number(s) and copies of identification documents, for example your driving license or passport, or a utility bill.
We use third party payment providers such as Paypal and gocardless to collect payments and we do not therefore store any payment details.
Additional verification information
We may ask you to send us additional information if:
- we cannot verify the information you provide; or
- as is otherwise required in order for us to comply with our obligations under money laundering regulations.
When we communicate
When you communicate with us for customer service or other purposes, including by phone, email or using other methods, we retain that information and our responses to you.
We MAY record details of meetings, discussions and calls either directly on the online coaching platforms we administer or licence or on other software support programmes eg: Pipedrive, Mailchimp. Etc. Any information you disclose to us will be held on these databases, with the exception of debit card numbers, which are not recorded to comply with The Payment Card Industry Data Security Standard.
As part of our holistic coaching approach you might disclose sensitive personal information, including the state of your health, in any communication, and if you should do so, you consent for us to hold that information in our records. (see further details below).
Information we collect when you use our website or app
When you arrive at or leave the New Level Results websites, listed as:
whether connected by a fixed line or wirelessly, we receive the web address of the site that you came from or are going to.
While you are using our site we collect information on the services you search for or view, page response times and length of visits to specific pages, how you interacted with each page (including scrolling, clicks and mouse-overs), and methods used to browse away from the page.
We collect information about the device you are using, such as the type of device, operating system and platform, the type and version of browser, browser plug-in types and versions, the times you access our website/app and the time zone setting, mobile network information and unique device identifier, which may include your Device’s IMEI number and/or MAC address, or the mobile phone number used by the Device. We do not capture GPS information about you.
If it is necessary for you to provide personal information about other individuals in the course of dealing with us, for example regarding directors and shareholders of a company, or the other party to a joint account, you should do so only where you are authorised by those individuals.
Although the information on Connected Parties and/or Recipients is stored for a certain period of time in compliance with applicable law, we will not use it to market to the non-registered person.
We may collect information you have chosen to make publicly available on social media sites. Where we are one of your connections on a social media site, we may also connect information you have chosen to share with your connections on that site.
Information about you from other sources
We may receive information about you if you use any of the other websites we, or our group companies, operate or the other services we provide. We are also working closely with third parties (including, for example, business partners and affiliates, customers who participate in our refer-a-friend programme, service providers, advertising networks, analytics providers, and search information providers) and may receive information about you from them, PROVIDED THESES PROVIDERS HAVE YOUR CONSENT TO DO SO. This may be combined with the information you provide to us.
We will use information we receive from business partners for marketing purposes only if you have provided your consent to do so, either to the third party which collected the information, or to us.
Data privacy regulations prohibit the processing of ‘special categories of personal data’, also called ‘sensitive data’ unless you have given your consent.
Sensitive data includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning health, sex life or sexual orientation. There are also restrictions on processing of criminal convictions and offences.
To avoid infringing these restrictions, it is our policy that we do not ask for or collect any of the above data from you or any other party, so we therefore ask that you please do not reveal any sensitive data about yourself or others in any communication with us.
If you do reveal sensitive data, for example by phone or in an email, you will be giving express consent for us to process that information by storing the recording of the telephone call, or the email or other communication.
3. How we use your information
Our primary purpose in collecting your information is to provide you with a safe, smooth, efficient and customised experience. By submitting your information to New Level Results and using our services you agree that we may use your information for the following purposes:
Fulfilling your requests
We will use your information to:
- provide you with the information, products and services that you request from us, including providing you with proposals and quotes;
- complete any transaction you are undertaking with us; and
- administer any promotion, survey or competition that you enter via our website(s).
Compliance and risk management
Communication and customer service
We communicate with our users on a regular basis via email, phone and SMS to provide requested services and help you manage your account. These activities include:
- responding to requests for customer service;
- confirming information concerning a user’s identity, business or account activity;
- informing users if we believe their accounts or any of their transactions have been used for an illegitimate purpose;
- resolving customer complaints;
- carrying out collection activities;
- resolving disputes about billing or transactions;
- conducting customer surveys; and
- investigating suspicious transactions.
We use your email to:
- confirm your opening of a New Level Results account;
- send you reminders electronically in respect of goals you have set up on your account;
- send you information about important changes to our products and services, including notice of any times that our services may not be available; and
- send notices and other disclosures required by law.
Users cannot opt out of these communications, but they will be primarily service-oriented rather than promotional.
As we are obligated to send these communications to current customers, if you do not wish to receive these communications at all, then unfortunately you must close your account, however if you do not wish to receive them in a particular way, please contact us to advise us of your preferred communication method.
We may also use your email address to send you other types of communications that you can control, including market updates, customer surveys and special promotions. These communications are to:
- provide you with information about services we offer that are similar to those that you have already enquired about or purchased;
- provide news about our company, marketing and advertising messages, updates on the services we offer, and promotional offers based on your activities when using our services;
- measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, which may be based on your activity on our website(s) or third parties’ websites;
- make suggestions and recommendations to you and other users of our website(s) about services that may interest you or them, which may be based on your activity on our website(s);
- keep you informed about events and news; and
- tell you about new products and features we are developing that you may find useful.
You can choose whether to receive some, all or none of these communications and the methods by which you receive them when you request a quote, enquire or complete the registration process (or at any time thereafter) by unsubscribing, by sending an email to firstname.lastname@example.org or by calling us and amending your preferences over the phone. We may also send you SMS messages for the same purposes.
Service improvements and account management
We will use your information to deliver and improve New Level Results Services and manage your account, including:
- verifying your identity, including during account creation and password reset processes;
- resolving disputes, collecting fees and troubleshooting problems;
- allowing us to manage risk and to detect, prevent, and/or remediate fraud or other illegal or prohibited activities;
- detecting, preventing or remediating violations of our policies, Terms and Conditions or other user agreements;
- providing you with customer support services including notifying you of changes to our service, including any outages, and to send you service emails relating to your account and transactions on your account;
- improving our existing, and developing new, products, services, websites, apps and capabilities;
- administering our website(s) and for internal business administration and operations purposes, including storage, backup, archiving, troubleshooting, data analysis, testing, research, statistical and survey purposes; and
- as part of our efforts to keep our site safe and secure, including managing and protecting our information technology infrastructure.
We will use this information to:
- administer our website(s) for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- improve our website(s) to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our website(s) and the app safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our website(s) and the app about goods or services that may interest you or them;
- to verify your identity, protect against fraud, comply with anti-financial crime laws and to confirm your eligibility to use our products and services; and
- to comply with our regulatory obligations.
Location information / IP (Internet Protocol) address:
We will use information about your location, derived from your IP address:
- to deliver relevant advertising to you, for example, information on tailored money transfer services for your region; and
- to protect against fraud
Third party information
We will combine third party information with information you give to us and that we collect about you. We will use all of this information:
- to help us better understand your coaching objectives;
- to process applications for products and services available through us.
Questionnaires, surveys, competitions and profile data
From time to time we may offer you optional questionnaires, surveys and competitions. If you choose to answer these questionnaires, surveys or competitions, we may use your information to improve New Level Results Services, send you marketing or advertising information, manage the competitions and for such purposes as collecting demographic information or assessing users’ interests and needs. You will be given notice of how the information will be used prior to your participation in the survey, questionnaire or competition.
Accessing and changing your information
You can request and amend the information you have provided to us by emailing us at email@example.com
5. Sharing information with third parties
To support our business and provide services to you
Just like most service providers, New Level Results works with third-party service providers (including Empatico and Best Year Yet) who provide important functions that allow us to compliment our coaching service offer.
This includes business partners under contract with us who support our business operations, such as fraud prevention, bill collection, marketing, customer service, contract administration and technology services. We need to disclose user data to them from time to time so that the services can be performed.
Banks and payment providers
When you ask us to process a payment transaction, we will provide your information to the business partners who are contracted to New Level Results to complete this transaction, for example passing bank details to correspondent bank(s) or payment provider(s) involved in the transaction.
Where required by law
We may disclose necessary information to the police and other law enforcement agencies, security forces, competent governmental, intergovernmental or supranational bodies, competent agencies, departments, regulatory authorities, self-regulatory authorities or organisations, and other third parties, including New Level Results and associated companies, where we are legally compelled and/or permitted to do so.
Mergers and acquisitions
Analytics and search engine providers
Affiliates & Associate Coaches
If you are referred to us by a third party – either via our affiliate network or via the refer-a-friend promotion – depending on the arrangement, we may notify them when you book a transaction.
We have a select group of associates and affiliates to whom we occasionally refer customers. If we think you may benefit from these services, we will ask you if you would like us to pass on your details. We will always name the associate and affiliate and ask you for permission before we refer you, and we will pass on your details only where you give us permission to do so. If we refer you, we will typically pass on your name, email address and telephone number.
Third party websites
Our site may, from time to time, contain links to the websites of our business partners, advertisers and affiliates.
If you request a quote directly on a third-party website or via a third party application, any information that you enter on that website or application (and not directly through New Level Results website) may be shared with the owner of any such third party website.
Please note that these websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any information to third party websites.
6. Transferring data overseas
New Level Results is committed to adequately protecting your information regardless of where the data resides and to providing appropriate protection for your information where such data is transferred outside of the EEA.
The laws in some countries may not provide as much legal protection for your information as in the EEA. In these circumstances, our policy to protect your data is to rely on findings of adequacy by the European Commission (for countries in scope of those findings), the EU-US Privacy Shield (for transfers to the USA) or standard contractual clauses adopted by the European Commission or the UK Information Commissioner (for all other countries).
We will do our best to protect your information, however we cannot guarantee the security of your information transmitted to our site or sent to us by email or other non-secure electronic methods; any such transmission is at your own risk. Once we have received your information, we will use protective procedures and security features to try to prevent unauthorised access.
7. Data Retention Policy
If you have a coaching plan, we will archive this 12 months after the date of expiry, unless you expressly ask us in writing to delete all your information.
However, we will retain account data for 7 years after the closure of an account. In some circumstances, such as an enquiry from a law enforcement agency, we may have to hold it longer. We may also retain information if required to protect our interests, for example in case of litigation. When data falls outside those retention periods we will take steps to delete it from our system. Where you have asked us not to contact you, we will retain that information on a ‘do not contact’ list to reduce the risk of us contacting you in the future.
8. Systems Security Policy
System security and monitoring
To ensure data privacy, confidentiality and integrity, all information disclosed, shared, stored or used and any transactions performed by you through our website and app are encrypted.
To provide a secure environment for our website, we hold your data in secure data centres with high levels of physical and technical security, including using firewall systems, data encryption and anti-virus protection. We use security surveillance systems to detect and prevent illegitimate access to and activities on our systems. External security experts conduct regular security reviews on our systems and we work with them to keep abreast of information security technology developments and implement relevant enhancement.
To control access to our services, every customer is required to input a Username and Password. To help us protect your information, you are advised to do the following:
- Do not choose a password that could be easily guessed by another person.
- Avoid using personal information such as your name, birth date or telephone number, or ordinary words found in a dictionary.
- Memorise your password – do not write it down.
- Never reveal the password to anyone else. We will never ask you for your password and you should not disclose it to anyone claiming to work for us or our business partners.
- Do not use the same password on other services.
We keep our security technology up-to-date to protect your information, but we do not have control over the devices you use to access New Level Results Services.
It is your responsibility to safeguard your online information and transactions by taking all reasonable measures which may include the following:
- Do not share your information or provide any opportunities for anyone to gain access to your information through your devices, including tablets, phones, watches or laptops.
- Log out and close your browser before visiting other websites once you have completed your transactions.
- Ensure that you use the latest version of your internet browser and that you have up-to-date anti-virus, firewall and other security software installed on your device.
9. Customer rights
You have the following rights:
To ask us to correct any information we hold about you if it is incorrect.
Whilst we endeavour at all times to keep your information accurate, we welcome your corrections. You can correct your profile at any time by logging onto your account via the New Level Results website, or you can call your coach or our support team to make any changes. We may ask you for additional verification information if you are changing certain details such as your name or your address.
To ask us to erase your information if we no longer have any reason to hold it, also known as the ‘right to be forgotten’.
Our Data Retention Policy (see section 7) explains the circumstances when we can or are obliged to retain information, however outside of those periods we will delete your information in line with our data retention policy and on request. We will maintain a record that you made an erasure request to reduce the likelihood of us contacting you in the future but we will use that information for no other purpose.
To ask us to return to you information you provided to us, also known as ‘data portability’.
You can ask us to send you in electronic format the information you provided to us under our Terms and Conditions or under consent.
To ask us not to process your information where you previously gave consent or where we are exercising our legitimate interest.
If you make a request for us to stop processing your information, we will investigate to see if there is a compelling reason for processing to continue and will discuss the conclusion of the investigation with you.
If you make a request for us to stop processing your information, we will investigate to see if there is a compelling reason for processing to continue and will discuss the conclusion of the investigation with you.
To ask not to be subjected to automated decision making and profiling.
New Level Results puts the human factor at the heart of our customer service, so there are no circumstances when profiling or other automated decision making will have a legal impact on you without a person reviewing and making a decision on the result. If you feel you may have been unfairly impacted by profiling, our team can manually assess whether the decision is fair and discuss the situation with you.
To ask for a copy of the information we hold about you.
We will endeavour to respond to your request within 30 days, however at time of high demand we may need 90 days to compile a full response.
To ask us not to process your information for marketing purposes.
You can do this by checking or unchecking certain boxes on the forms we use to collect your information, or by clicking on the ‘unsubscribe’ link(s) at the foot of every marketing or promotional email, or by emailing firstname.lastname@example.org
You may exercise any of the above rights by contacting us email@example.com or by contacting your coach directly.
10. Contacting us
The Data Controller
The Data Controller is New Level Results Limited, Registered office address 3 & 4 Park Court, Riccall Road, Escrick YORK, YO19 6ED, company registration number 09011028.
Contacting us with questions or requests
Complaints to the Data Protection Officer
If you believe that we have breached a privacy law with which we should comply, please send an email to firstname.lastname@example.org. We aim to respond in a reasonable time, normally within 30 days. Our Compliance team and Data Protection Officer will look after your complaint and will give you additional information about how it will be managed.
Complaints to the UK Information Commissioner
You have the right to complain to the UK Information Commissioner’s Office if you believe we have not handled your request in an appropriate manner. For information on contacting the ICO please see their website.