Personar – Privacy Policy
This
privacy policy explains how Personar ("we", "us"
or "the Company")
collects, uses and shares your personal information. It applies to the personal
information of coaches and athletes who use our CoachScribe App.
If you would like more
information on a specific section of this privacy policy please click on the
relevant link below.
Contents
1.
Contact
details
2.
Information
we collect, why and legal bases at a glance
3.
Where
we get personal information from
4.
Automated
decision-making
5.
International
transfers
6.
How
long we keep information
7.
Who
we share information with
8.
Security
of your information
9.
Data
protection rights
10.
How
to complain
1. Contact details
|
Controller |
Personar Limited a company registered in England and
Wales with company number 13435949 and whose registered address is at 71-75
Shelton Street, Covent Garden, London WC2H 9JQ |
|
Postal Address |
71-75 Shelton Street, Covent Garden, London WC2H 9JQ |
|
Email |
privacy@personar.ai |
|
Changes to this policy |
We
keep this policy under regular review. This version was last updated on 3rd
September 2026. Where we make any significant changes to this policy we will
notify you by email. |
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 (and please see the section ‘How to
Complain’ at the end of this privacy policy for more details). We would,
however, appreciate the chance to deal with your concerns first, so please
contact us in the first instance.
2. Information we
collect, why and legal bases at a glance
The
table below summarises each purpose for which we collect personal information,
the categories of personal data used for that purpose, and the legal basis we
rely on under the UK GDPR.
Please
note that this policy sets out details relating to us collecting personal data
for our own purposes (as set out below). It does not cover the personal data
that it collected by coaches during the coaching/mentoring sessions.
When
coaches are collecting data from athletes during a coaching/mentoring session,
using the CoachScribe App, we will process personal data (including special
category data relating to an athlete’s health) on behalf of the coach.
Please
note that we do not knowingly collect special categories of personal data
(such as data revealing race, ethnicity, religious beliefs, sexual orientation,
political opinions, trade union membership, health, or genetic/biometric data),
so please do not provide us with any such data.
The
coach should explain to you how they will collect, process and protect personal
data themselves via their own privacy policy.
|
Purpose |
Categories of personal
data |
Legal basis |
|
Providing
the CoachScribe App to coaches and athletes (including registering coaches
and athletes as users of the app and them creating an account) |
Names
and contact details of coaches and athletes; job title and occupation; skills
and qualifications. |
Performance of a contract |
|
Operating
and administering client accounts, including sharing data with the trusted IT
services providers we use to create, develop, maintain and host the
CoachScribe App |
Names
and contact details of coaches and athletes; job title and occupation; skills
and qualifications. |
Performance of a contract |
|
Record
Keeping during the Subscription Term (and for the relevant run-off period) |
Names
and contact details of coaches and athletes; job title and occupation; skills
and qualifications |
Compliance with a legal obligation |
|
Sending
updates and marketing communications |
Names
and contact details, such as email address |
Legitimate
interests and consent |
|
Data
analytics and insights using AI |
This
will use anonymised data and you cannot be identified as an individual |
Legitimate
Interests |
|
Managing
queries, complaints or claims (including under our internal data protection
complaints process) |
Names
and contact details; account records; and correspondence |
Performance
of a contract |
Where
we rely on consent, you can withdraw
it at any time without affecting prior processing. If you wish to withdraw your
consent please contact us using the details set out in section 1 above.
3. Where we get personal
information from
We
obtain personal information directly from you. We do not currently obtain
personal information about you from any other source.
4. Automated
decision-making
We use AI
to perform analytics on anonymised data that does not identify any individuals,
to improve the performance of the CoachScribe App. We do not carry out
automated decision-making that has legal or other significant effects on you.
5. Who we share
information with
We
use various IT service providers, including Microsoft Azure (for hosting our
technical infrastructure and cloud storage), GoDaddy for our general internal
systems (such as email) and Zoom (for our online meetings). Please email us at privacy@personar.ai
for a full list of the third party services providers we use and the purpose
for which we use them.
We
also use Apple and Google as our app store providers.
This
means that there is a technical sharing of data with them, as they process
personal data via their servers.
We
use Stripe as a trusted payment services provider.
We
use freelancers for our general business operations.
We
may share your personal data with our professional and legal advisers (such as
lawyers and accountants).
Please
note that we are not responsible for any information shared between coaches and
athletes or between coaches and their third party providers.
6. International
transfers
When
there is a transfer of personal data outside of the UK we understand the need
to have an appropriate level of protection is in place, such as the UK
International Data Transfer Agreement or the UK International Data Transfer
Addendum to the EU Standard Contractual Clauses or an applicable UK ‘Adequacy’ decision.
Further information about these safeguards please email us atprivacy@personar.ai.
7. How long we keep
information
As
a general principle, we do not keep personal information for any longer than is
necessary for the purposes set out in this privacy policy, having regard to our
contractual, legal and regulatory obligations. Our standard retention periods
are set out below.
|
Category of
information |
Retention period |
Basis for retention
period |
|
Coach
and athlete account data |
6
years from the end of the contract or business relationship |
Compliance
with a legal obligation |
|
Financial
and accounting records (invoices, payments) |
6
years from the end of the relevant financial year |
Compliance
with a legal obligation |
|
Complaints
and dispute records |
6
years from resolution of the complaint |
Compliance
with a legal obligation |
Further
information on our retention periods, and the criteria used to determine them,
is available on request. Please email us at privacy@personar.ai .
8. Security of your
information
We
understand our obligations to protect your personal data and so we have
technical and organisational measures in place. For more information about these
measures please contact us at privacy@personar.ai .
9. Data protection rights
You
have the following rights in relation to your personal information, subject to
certain exemptions:
•
Right
of access
– request copies of your personal information, and information about how we
obtained it and with whom it has been shared.
•
Right
to rectification
– ask us to correct or complete personal information you consider inaccurate or
incomplete.
•
Right
to erasure
– ask us to delete your personal information in certain circumstances.
•
Right
to restriction of processing – ask us to limit how we use your personal information.
•
Right
to object to processing
– object to our processing of your personal data in certain circumstances,
including processing based on legitimate interests.
•
Right
to data portability
– ask us to transfer the personal information you have provided to another
organisation, or to you.
•
Right
to withdraw consent
– where we rely on consent, withdraw that consent at any time.
Further
information on each right is available from the ICO.
We will respond to any such request
without undue delay and, in any event, within one month. To exercise any of
these rights, please contact us using the details set out above.
10.
How to
complain
If
you have a complaint in relation to how we have handled your personal
information, you may complain to us directly using the contact details set out
below:
|
Contact |
Data Privacy Manager |
|
Post |
71-75 Shelton Street, Covent Garden, London WC2H 9JQ |
|
Email |
privacy@personar.ai |
When we receive a complaint, we will:
•
Acknowledge receipt of your complaint within
30 days;
•
Investigate your complaint without
undue delay, keeping you updated on progress; and
•
Communicate the outcome to you without undue
delay, including the steps we have taken, any resulting action, and our
reasoning.
Complaining to the ICO. You also have the right to
lodge a complaint with the Information Commissioner’s Office (ICO) at any time,
whether or not you have first complained to us:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline:
0303 123 1113
Website: ico.org.uk/make-a-complaint
This privacy policy was last reviewed
on 3rd September 2026 and may be updated from time to time. We will
notify you by email of any material changes before they take effect, where
appropriate.