Your personal data – what is it?

“Personal data” is any information about an individual which allows them to be identified by, for example, a name, photographs, videos, email address, or address.

Identification can be directly using the data itself or by combining it with other information which helps to identify a living individual.

The processing of personal data is governed by legislation relating to personal data which applies in Canada and other legislation relating to personal data and rights such as the Human Rights Act.

Who am I?

This Privacy Notice is provided to you by which is the data controller for your data. and Jenn Kozak – Return to Self Coaching are trading names of Jennifer Kozak, “the company”.

Other data controllers the company works with:

To provide my service to you, I may share your data with my Email Marketing Platform, The Rocket Science Group LLC d/b/a MailChimp, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA, and our web host, SiteGround Hosting Ltd., 3rd Floor, 11-12 St. James’s Square, London SW1Y 4LB.

I may need to share your personal data I hold with them so that they can carry out their responsibilities to the company. If we and the other data controllers listed above are processing your data jointly for the same purposes, then the company and the other data controllers may be “joint data controllers” which mean we are all collectively responsible to you for your data.

Some of the services we sell are provided by external partners – domain registrars like Tucows and Open Provider, GlobalSign or Really Simple SSL for SSL certificates, Cloudflare for CDN, and others. They need a client’s data so they can deliver the service.

Where each of the parties listed above are processing your data for their own independent purposes then each of us will be independently responsible to you and if you have any questions, wish to exercise any of your rights (see below) or wish to raise a complaint, you should do so directly with the relevant data controller.

A description of what personal data the company processes and for what purposes is set out in this Privacy Policy.

The company will process some or all of the following personal data where necessary to perform its tasks:

Names; contact details such as telephone numbers, addresses, and email addresses.

How I use sensitive personal data

I may process sensitive personal data including, as appropriate:

In order to comply with legal requirements and obligations to third parties.

I may process special categories of personal data in the following circumstances:

In limited circumstances, with your explicit written consent.

Where I need to carry out my legal obligations.

Where it is needed in the public interest.

Less commonly, we may process this type of personal data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Do we need your consent to process your sensitive personal data?

In limited circumstances, we may approach you for your written consent to allow us to process certain sensitive personal data. If we do so, we will provide you with full details of the personal data that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

The company will comply with the General Data Protection Regulation 2018. This says that the personal data we hold about you must be:

Used lawfully, fairly and in a transparent way.

Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

Relevant to the purposes we have told you about and limited only to those purposes.

Accurate and kept up to date.

Kept only as long as necessary for the purposes we have told you about.

Kept and destroyed securely including ensuring that appropriate technical and security measures are in place to protect your personal data to protect personal data from loss, misuse, unauthorized access and disclosure.

We use your personal data for some or all of the following purposes:

To deliver services including the provision of online or in-person training services;

To understand your needs to provide the services that you request and to understand what we can do for you and inform you of other relevant services;

To confirm your identity to provide some services;

To contact you by email or telephone;

To enable us to meet all legal and statutory obligations and powers including any delegated functions;

To carry out comprehensive safeguarding procedures (including due diligence and complaints handling) in accordance with best safeguarding practice from time to time with the aim of ensuring that all children and adults-at-risk are provided with safe environments and generally as necessary to protect individuals from harm or injury;

To maintain our own accounts and records;

To seek your views, opinions or comments;

To notify you of changes to our facilities, services, events, and staff;

To send you communications which you have requested and that may be of interest to you. These may include information about new projects or initiatives;

To allow the statistical analysis of data so we can plan the provision of services.

What is the legal basis for processing your personal data?

The company has certain powers and obligations. Most of your personal data is processed for compliance with a legal obligation which includes the discharge of the company’s statutory functions and powers. We will always take into account your interests and rights.

This Privacy Policy sets out your rights and the company’s obligations to you.

We may process personal data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract.

Sometimes the use of your personal data requires your consent. We will first obtain your consent to that use.

Sharing your personal data

This section provides information about the third parties with whom the company may share your personal data. These third parties have an obligation to put in place appropriate security measures and will be responsible to you directly for the manner in which they process and protect your personal data. It is likely that we will need to share your data with some or all of the following (but only where necessary):

The data controllers listed above under the heading “Other data controllers the company works with”;

Our agents, suppliers, and contractors. For example, we may ask a commercial provider to publish or distribute newsletters on our behalf, or to maintain our database software;

On occasion, other companies with which we are carrying out joint ventures.

We only work with partners that are GDPR-compliant.

How long do we keep your personal data?

We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time.

We may have legal obligations to retain some data in connection with our statutory obligations. The company is permitted to retain data in order to defend or pursue claims. In some cases, the law imposes a time limit for such claims (for example 3 years for personal injury claims or 6 years for contract claims).

We will retain some personal data for this purpose as long as we believe it is necessary to be able to defend or pursue a claim. In general, we will endeavor to keep data only for as long as we need it. This means that we will delete it when it is no longer needed.

Your rights and your personal data

You have the following rights with respect to your personal data:

When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases, we will need you to respond with proof of your identity before you can exercise these rights.

The right to access personal data we hold on you

At any point, you can contact me request the personal data we hold on you as well as why we have that personal data, who has access to the personal data and where we obtained the personal data from. Once we have received your request we will respond within 30 days.

There are no fees or charges for the first request but additional requests for the same personal data or requests which are manifestly unfounded or excessive may be subject to an administrative fee.

The right to correct and update the personal data we hold on you

If the data I hold on you is out of date, incomplete or incorrect, you can inform me and your data will be updated.

The right to have your personal data erased (“Right to be forgotten”)

If you feel that we should no longer be using your personal data or that we are unlawfully using your personal data, you can request that we erase the personal data we hold.

When we receive your request we will confirm whether the personal data has been deleted or the reason why it cannot be deleted (for example because we need it for to comply with a legal obligation).

The right to object to the processing of your personal data or to restrict it to certain purposes only

You have the right to request that we stop processing your personal data or ask us to restrict processing.
Upon receiving the request we will contact you and let you know if we are able to comply or if we have a legal obligation to continue to process your data.

The right to data portability

You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within 30 days of receiving your request.

The right to withdraw your consent to the processing at any time for any processing of data to which consent was obtained

You can withdraw your consent easily by telephone, email, or by post (see details below).

The right to lodge a complaint at Canada’s Office of the Privacy Commissionerwhich is overseeing compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s private sector privacy law.

Transfer of Data Abroad

Any personal data transferred to countries or territories outside the European Economic Area (“EEA”) will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union. My website is also accessible from overseas so on occasion some data (for example in a newsletter) may be accessed from overseas.

Further processing

If I wish to use your personal data for a new purpose, not covered by this Privacy Policy, then I will provide you with a new statement explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, I will seek your prior consent to the new processing.

Changes to this notice

I keep this Privacy Policy under continued review and I will place any updates on

This Policy was last updated on 15 March 2019.

Contact Details

Please contact me if you have any questions about this Privacy Policy or the personal data I hold about you or to exercise all relevant rights, queries or complaints at or Return to Self Coaching 68 Crystal Shores Place, Okotoks, T1S 2G3 (AB).