Privacy Policy

1. Introduction

Your privacy is important to us. This privacy statement explains what different kinds of personal data Blush Cloud Ltd. collects from you, through our interactions with you and through our products, how we use that data and what are your rights as a data subject. Blush Cloud Ltd. offers a wide range of services from coaching, online products, mentoring consulting and D&I training as well as original content and reference content. 

2. Disclaimer

2.1 Liability for Content

We make every effort to keep the information on our website current but accept no liability whatsoever for the content provided. The law limits our responsibility as a service provider to our own content on these webpages. We are not obligated to monitor third-party information provided or stored on our website. However, we shall promptly remove any content upon becoming aware that it violates the law. Our liability in such an instance shall commence at the time we become aware of the respective violation.

2.2 Liability for Links

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information that you provide while visiting such sites and such sites are not governed by this privacy statement. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. You should exercise caution and look at the privacy statement applicable to the website in question. At the time any third-party websites were linked to, we found no grounds whatsoever of any likely contravention of the law. We shall promptly delete such links upon becoming aware that any of them violate the law.

2.3 Copyrights

The content and works provided on these Web pages are governed by the copyright laws of the United Kingdom. Duplication, processing, distribution, or any form of commercialization of such material beyond the scope of the copyright law shall require the prior written consent of its respective author or creator.

3. Data Protection and Privacy Policy

Our core beliefs regarding user privacy and data protection:
          - User privacy and data protection are human rights.
          - Blush Cloud Ltd. has a duty of care to the people within our data.
          - Data is a liability, it should only be collected and processed when necessary.
          - Blush Cloud Ltd. will never sell, rent or otherwise distribute or make public your personal information.
          - Blush Cloud Ltd. takes its security obligations seriously in respect of your personal data under the EU General Data Protection Regulation (GDPR).

By contacting us through our contact forms and sources requesting forms on our websites, through a 3rd party website that forwards your information upon your request to us, or through any other form through which your personal information is provided to us, or by visiting our website, you are agreeing to this policy and the procedures stated within. Your data is accessible only by approved staff members within Blush Cloud Ltd. or contractors hired by Blush Cloud Ltd. to do work with set data exclusively within the consent you have already provided. If you are under 16 years of age, you must obtain parental consent before contacting us.

3.1 Relevant Legislation

This website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
         EU General Data Protection Regulation 2018 (GDPR)

This site’s compliance with the above legislation means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. 

3.2 Personal information that this website collects and what we do with it

Again, we take your privacy very seriously and are committed to keeping your information safe and secure. We do not sell, license, lease or otherwise disclose your personal information to any third party outside Blush Cloud Ltd. for any reason except as noted earlier and as described below:
          - Blush Cloud Ltd. uses the data we collect from you to provide you with an invoice or receipt for purchased services.
          - We also use the information collected to communicate with you regarding enquiries you have made, to book, change or cancel an agreed appointment in the event of an emergency or unexpected situation and to advise you of any useful information that may come to our attention which is related to your original enquiry. 
          - With your permission, it may be used to add you to a mailing list, log coaching hours for upgrading coaching qualifications or as part of legal or insurance requirements.
          - Information may be shared with contracted 3rd parties who assist in providing support for our internal operations.
          - Information that you give us and information about your participation in the Site(s) and our Service may be combined with other personally identifiable information (such as demographic information and past purchase history) available from our records and other sources. This information will be used to make our future marketing efforts more efficient.
          - From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy policy. If our information practices materially change at some time in the future, we will post the policy changes to the Site(s), will note this in section 4 and if requested we will provide you with a copy of the revised privacy policy at the primary email address you provide to us.
          - The information we collect may be disclosed when we are legally required to do so, at the request of governmental authorities conducting an investigation, to verify or enforce compliance with the policies governing our website and applicable laws, or to protect against misuse or unauthorized use of our website.

You have the right to access your data, the right for data portability and the “right to be forgotten”. More details on this can be found in section 3.6.4. If you would like to request any of this, please contact us via the email - databases are being reviewed regularly and private data that is not relevant to us any more will be deleted by us.

3.3 Visiting the website and contacting us

3.3.1 Site visitation tracking and cookies

Necessary, Marketing and Google Analytics Cookies

Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.

Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you, but Google does not grant us access to this. We consider Google to be a 3rd party data processor.

GA makes use of cookies, details of which can be found on Google’s developer guides

Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website. The website does not track unless you have explicitly agreed to it.

3.3.2 Mailing List

If you contact us, you consent to receive specific marketing emails from us that fit to your enquiry. The email address and information that you submit to us will be forwarded to contracted 3rd parties, who provide us with marketing and software services.

We consider these providers to be 3rd party data processors (see section 3.6 below). The email address and further information that you submit will not be stored within this website’s own database.

Your data will remain within these parties’ database for as long as we continue to use their services or until you specifically request removal. You can do this by requesting removal via email. When requesting removal via email, please send your email to the person who contacted you and using the email account that you have contacted us through.

You can opt-out of receiving automated emails from us by emailing to let us know your specific wishes. We will respond to the request within 10 working days. 

3.3.3 Summary of additional Cookies used on our website

At present Blush Cloud is not using additional cookies. Should we decide to take advantage of such services, additional information will be added

3.4 Our 3rd party data processors

The third parties mentioned in this section have been carefully chosen and all of them comply with the legislation set out in All of the third parties that are based in the USA are EU-U.S. Privacy Shield compliant.

3.4.1 Visiting our website

We use third parties to process personal data on our behalf when you visit our website.
          - Google (Privacy policy)
          - Webflow (Privacy policy)

3.4.2 Contacting us

When you submit your information in one of our contact forms your information might be stored and processed on a 3rd CRM. On top of that, your information may be passed to a relevant person within Blush Cloud Ltd. to answer your query and they may reach out to you via email or phone, or by trying to connect with you on a social media platform like LinkedIn.

3.5 Data Breaches

We will report any unlawful data breach of this website’s database or the database(s) of any of our 3rd party data processors to any and all relevant persons and authorities within seventy-two (72) hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.

3.6 Your right as a data subject

As a data subject (this can be a member of Blush Cloud Ltd. whose data is held by us or any subject outside the Blush Cloud Ltd.) whose personal information is held by any member of Blush Cloud Ltd., you have certain rights.

If you wish to exercise any of these rights, please email use the information supplied you by Blush Cloud Ltd.

In order to process your request, we will ask you to provide valid forms of identification for verification purposes.

Your rights are as follows:

3.6.1 The right to be informed

As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy policy and any related communications we may send you.

3.6.2 The right of access

You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
          - The purposes of the processing#
          - The categories of personal data concerned
          - The recipients to whom the personal data has been disclosed
          - The retention period or envisioned retention period for that personal data
          - When personal data has been collected from a third party, the source of the personal data

If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.

3.6.3 The right to rectification

When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.

3.6.4 The right to erasure (the ‘right to be forgotten’)

Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.

3.6.5 The right to restrict processing

You may ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:
          - The accuracy of the personal data is contested
          - Processing of the personal data is unlawful
          - We no longer need the personal data for processing, but the personal data is required for part of a legal process
          - The right to object has been exercised and processing is restricted pending a decision on the status of the processing

3.6.6 The right to data portability

You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation

3.6.7 The right to object

You have the right to object to our processing of your data where
          - Processing is based on legitimate interest;
          - Processing is for the purpose of direct marketing;
          - Processing is for the purposes of scientific or historic research;
          - Processing involves automated decision-making and profiling.

3.7 Data Controller

The data controller of this website is:
Blush Cloud LTD
Company number: 12975946

3.8 Data Protection Officer & Contact

We are not a public authority and our core activities do not:
          - require large scale, regular and systematic monitoring of individuals (for example, online behavior tracking); or
          - consist of large scale processing of special categories of data or data relating to criminal convictions and offences,

and therefore, are not obligated to appoint a Data Protection Officer (DPO).
If you have questions about our data privacy or your personal data, you can contact us

4. Changes to our Policies

This privacy policy may change from time to time in line with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes.

We will only reach out to you and inform you about changes to this privacy policy if the changes are significant.

Last Update 23th November 2020