ENGINEERING SUCCESS VG PRIVACY POLICY
1.Important information and who I am
This privacy policy gives you information about how I collect, use and look after your personal data when you visit my website, fill in the contact form, sign up to receive information from me, purchase services from me (whether through my website or by direct interaction between us) or take part in a survey. This policy also tells you about your privacy rights and how the law protects you.
I collect, use and am responsible for certain personal information about you. When I do so I am subject to data protection laws which apply across the European Union and the United Kingdom and I am responsible as ‘controller’ of that personal information for the purposes of those laws.
This website is not intended for children and I do not knowingly collect data relating to children.
Controller
Valentina Guerra (t/a Engineering Success VG) is the controller and responsible for your personal data (referred to as “I”, “me” or “my” in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact me (see paragraph 10).
2. The types of personal data I collect about you
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
I may collect, use, store and transfer different kinds of personal data about you which I have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
- Contact Data includes billing address, postal address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from me.
- 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 purchases or orders made by you, your feedback and survey responses.
- Usage Data includes information about how you interact with and use my website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from me and my third parties and your communication preferences.
I 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, I may aggregate your 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 my website to help improve the website and my service offering.
Sensitive Data
Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, and criminal convictions and offences.
I do not collect any sensitive data about you.
3. How is your personal data collected?
I use different methods to collect data from and about you including through:
- Your interactions with me. You may give me your personal data by filling in online forms or by communicating with me by email or other electronic correspondence, by telephone or by using video conferencing software. This includes personal data you provide when you:
- enquire about or purchase my services;
- engage in my coaching sessions;
- subscribe to my newsletter or other publications;
- request marketing to be sent to you;
- enter a survey; or
- give me feedback or contact me.
- Automated technologies or interactions. As you interact with my website, I may automatically collect Technical Data about your equipment, browsing actions and patterns. I collect this personal data by using cookies and other similar technologies. Please see my cookie policy for further details.
- Third parties or publicly available sources. I will receive personal data about you from various third parties and public sources as set out below:
- Technical Data is collected from the following parties:
- analytics providers such as Google;
- advertising networks;
- social media platforms where you interact with Engineering for Success accounts and my professional social media handles; and
- search information providers.
- Contact, Financial and Transaction Data is collected from providers of payment services such as Stripe.
- Contact Data is collected from third party referrers and social media platforms.
4. How I use your personal data
Legal basis
I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:
- Performance of a contract with you: Where I need to perform the contract I am about to enter into or have entered into with you.
- Legitimate interests: I may use your personal data where it is necessary to conduct my business and pursue my legitimate interests, for example to enable me to give you the best and most secure client experience. I make sure I consider and balance any potential impact on you and your rights (both positive and negative) before I process your personal data for my legitimate interests. I do not use your personal data for activities where my interests are overridden by the impact on you (unless I have your consent or am otherwise required or permitted to by law).
- Legal obligation: I may use your personal data where I need to comply with a legal or regulatory obligation.
- Consent: I rely on consent only where I have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter via my website. You have the right to withdraw consent to marketing at any time by emailing me at info@engineeringsuccess.co.uk or by clicking on the ‘unsubscribe’ button in my emails.
Purposes for which I will use your personal data
I have set out below, in a table format, a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so. I have also identified what my legitimate interests are where appropriate.
Note that I may process your personal data for more than one lawful ground depending on the specific purpose for which I am using your data.
Purpose/Use | Type of data | Legal basis |
To register you as a new client | (a) Identity (b) Contact | Performance of a contract with you |
To process your order and deliver my services to you, including: (a) Manage payments, fees and charges (b) Collect and recover money owed to me (c) Contact you between sessions and over the course of a coaching programme | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for my legitimate interests (to recover debts due to me) |
To manage my relationship with you which will include: (a) Notifying you about changes to my terms or privacy policy (b) Dealing with your requests, complaints and queries | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for my legitimate interests (to keep my records updated and manage my relationship with you) |
To enable you to complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for my legitimate interests (to study how clients use my services, to develop them and grow my business) |
To administer and protect my business and my website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for my legitimate interests (for running my business, provision of administration and IT services, network security, to prevent fraud and in the context of any business restructure) (b) Necessary to comply with a legal obligation |
To deliver relevant website content to you and measure or understand the effectiveness of the content I serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for my legitimate interests (to study how clients use my services, to develop them, to grow my business and to inform my marketing strategy) |
To use data analytics to improve my website, services, client relationships and experiences and to measure the effectiveness of my communications, marketing and services | (a) Technical (b) Usage | Necessary for my legitimate interests (to define types of clients for my services, to keep my website updated and relevant, to develop my business and to inform my marketing and overall business strategy) |
Sending marketing communications based on your Profile Data and my direct interactions with you (see more on this in the “Using personal data for marketing” section below) | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | (a) Necessary for my legitimate interests (to develop my services and grow my business) (b) Consent, having obtained your prior consent to receiving direct marketing communications |
To promote my business, using third-party marketing companies and tools. These include Google, Mailchimp, Facebook and LinkedIn | (a) Usage (b) Technical Note that Google may combine the personal data I disclose with other data it already has | Necessary for my legitimate interests (to define types of clients for my services, to keep my website updated and relevant, to develop my business and to inform my marketing strategy) |
Using personal data for marketing
I may analyse your Identity, Contact, Technical, Usage and Profile Data to form a view on which services and offers may be of interest to you so that I can then send you relevant marketing communications.
If you receive such communications from me and do not wish to, you can tell me by using the unsubscribe link in any email I send to you or emailing me at info@engineeringsuccess.co.uk
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, appointment reminders, updates to my Terms and Conditions and checking that your contact details are correct.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of my website may become inaccessible or not function properly. For more information about the cookies I use and how to change your cookie preferences, please see my cookie policy.
5. Disclosures of your personal data
I may share your personal data where necessary with the parties set out below for the purposes set out in section 4 above:
- External third parties such as service providers, professional advisers, HMRC and other public authorities.
- Third parties to whom I may choose to sell or merge part or all of my business. Alternatively, I may seek to acquire other businesses or merge with them. If a change happens to my business, then the new owners may use your personal data in the same way as set out in this privacy policy.
I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow my third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with my instructions. Note that certain third-party service providers (for example, training platforms, as well as collaboration platforms such as Zoom) are data controllers. This means that they are the main decision-makers – they exercise overall control over the purposes and means of the processing of personal data. These service providers will provide you with their own privacy policies explaining how and why your personal data is collected and processed by them.
I 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 I transfer your personal data outside the UK to service providers, I ensure a similar degree of protection is afforded to that data, whether by specific standard contractual terms approved for use in the UK, an approved certification scheme or because the relevant country has been deemed by the UK to provide an adequate level of protection for personal data. Please contact me (see paragraph 10) if you would like additional details.
I 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, I 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 my instructions and they are subject to a duty of confidentiality.
I 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 I am legally required to do so.
How long will you use my personal data for?
I will only retain your personal data for as long as reasonably necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, regulatory, tax or accounting requirements. I may retain your personal data for a longer period in the event of a complaint or if I reasonably believe there is a prospect of litigation in respect to my relationship with you.
To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law I have to keep basic information about my clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.
In some circumstances you can ask me to delete your data: see paragraph 9 below for further information.
In some circumstances I may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case I may use this information indefinitely without further notice to you.
You have a number of rights under data protection laws in relation to your personal data. In summary, these include rights 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 I hold about you and to check that I am lawfully processing it.
- Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to me.
- Request erasure of your personal data in certain circumstances.
- Object to processing of your personal data where I am 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 my legitimate interests). In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your right to object.
- Object at any time to the processing of your personal data for direct marketing purposes.
- Request the transfer of your personal data to you or to a third party. I will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
- Withdraw consent at any time where I am relying on consent to process your personal data (see the table in section 4 for details of when I 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, I may not be able to provide certain services to you. I will advise you if this is the case at the time you withdraw your consent.
- Request restriction of processing of your personal data in certain circumstances.
For further information on each of these rights, including the circumstances in which they apply, see this ICO Guidance.
If you wish to exercise any of the rights set out above, please contact me (see 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, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I could refuse to comply with your request in these circumstances.
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 me at info@engineeringsuccess.co.uk.
11. 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). I would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact me in the first instance.
12. Changes to the privacy policy and your duty to inform me of changes
I keep my privacy policy under regular review. This version was last updated in April 2025.
It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship with me, for example a new address or email address.
From time to time I may provide you with hyperlinks to, and details of, third party websites. In general, I have no control over and am not responsible for, the privacy policies and practices of third parties.
Some of my third party service providers may handle your personal data as a controller in their own right (for example, collaboration platforms such as Zoom, and also where I use a third party training platform). This will tend to be the case when you are asked to register directly with the service provider in order to access my services. Any information you provide to these services providers will be subject to their own privacy policy so please review them to see how they will handle your personal data. or email address.
14. Data protection registration
I am registered as a data controller with the UK Information Commissioner’s Office. My data protection registration number is ZB855623.