WHO IS RESPONSIBLE FOR YOUR DATA?
For the personal data described in this policy, the data controller is:
WHAT DATA MAY BE COLLECTED?
The information collected depends on how you interact with FRAYMARK.
When you contact FRAYMARK
This may include your name, email address, telephone number, company or organisation, website, the subject of your enquiry, and anything you choose to include in your message.
When you book a session
This may include your name, contact information, company details, appointment information, booking preferences and information necessary to arrange and administer the session.
When you complete the pre-session intake
This may include information about your business, its people, processes, operations, systems, tools, decision-making, challenges, goals and anything else you voluntarily provide in preparation for the session.
When you make a payment
Payment information is processed through the payment provider made available during checkout. FRAYMARK may receive transaction information such as payment status, amount, date, transaction reference and limited billing information.
FRAYMARK does not need to receive your full payment-card number in order to administer your booking.
When you use the website
Technical data may be processed automatically, such as IP address, browser or device information, pages visited, timestamps and cookie or similar technology information, depending on the services enabled on the website and your consent choices where consent is required.
WHY IS YOUR DATA USED?
Personal information may be used to:
- respond to enquiries;
- arrange and administer appointments;
- process and confirm payments;
- prepare for and deliver Strategic Clarity Sessions;
- create and provide agreed client deliverables;
- communicate before and after a session;
- maintain appropriate client and business records;
- operate, secure and improve the website and business systems;
- prevent misuse, fraud or security incidents;
- meet accounting, tax, regulatory and other legal obligations;
- establish, exercise or defend legal claims where necessary.
WHAT IS THE LEGAL BASIS?
Under the GDPR, personal data must be processed on an appropriate legal basis. Depending on the situation, FRAYMARK may rely on one or more of the following:
Steps before entering a contract
Where you contact FRAYMARK about a possible service or take steps toward booking an engagement.
Performance of a contract
Where processing is necessary to provide a service you have booked or purchased.
Legal obligation
Where information must be kept or processed to comply with tax, accounting or other applicable legal requirements.
Legitimate interests
Where processing is reasonably necessary to operate, administer, protect or improve FRAYMARK, provided those interests do not override your rights and freedoms.
Consent
Where the law requires consent, for example for certain non-essential cookies or particular marketing communications. You may withdraw consent for future processing at any time.
FRAYMARK does not need every piece of information about you. The aim is to collect what is reasonably necessary to respond, work with you, administer the relationship and meet legal obligations.
WHO MAY PROCESS YOUR DATA?
FRAYMARK uses third-party services to operate the website, booking system, communications, client administration and payments. Those providers may process personal information where necessary to provide their services.
HighLevel / LeadConnector
FRAYMARK uses HighLevel-powered systems for functions that may include website pages, forms, surveys, contact management, booking, communications, workflows and client administration.
Payment providers
Payments may be processed by payment providers made available at checkout, such as Stripe and, where enabled, PayPal. Those providers process information in accordance with their own contractual and privacy obligations.
Other service providers
FRAYMARK may also use professional, technical, hosting, communications, meeting, accounting or other service providers where reasonably necessary to operate the business.
Personal data is not sold by FRAYMARK.
INTERNATIONAL DATA TRANSFERS
Some technology providers used by FRAYMARK may process or store information outside France or the European Economic Area.
Where GDPR-protected personal data is transferred internationally, FRAYMARK seeks to use providers and contractual mechanisms that provide an appropriate basis for those transfers, such as adequacy arrangements, applicable data-transfer frameworks, Standard Contractual Clauses or other safeguards recognised under applicable data-protection law.
HOW LONG IS DATA KEPT?
Personal information is kept only for as long as reasonably necessary for the purpose for which it was collected and for any applicable legal, accounting, tax, contractual or dispute-resolution requirements.
Different types of information may therefore have different retention periods.
When information is no longer required, FRAYMARK will take reasonable steps to delete it, anonymise it or otherwise cease using it, subject to any legal requirement to retain it.
YOUR DATA-PROTECTION RIGHTS
Depending on the circumstances and applicable law, you may have rights concerning your personal data.
To make a privacy request, email [email protected] .
FRAYMARK may need to verify your identity before acting on a request where appropriate.
COMPLAINTS
If you have a concern about how your personal data is being handled, you are encouraged to contact FRAYMARK first so the matter can be reviewed.
You also have the right to lodge a complaint with the competent supervisory authority.
In France, the supervisory authority is the Commission Nationale de l'Informatique et des Libertés (CNIL).
COOKIES AND SIMILAR TECHNOLOGIES
The website may use cookies or similar technologies that are necessary for core website functionality, security, forms, booking or other services.
Where non-essential cookies or comparable technologies are used and applicable law requires consent, they should only be activated in accordance with the consent choices presented to you.
The specific technologies in use may change as website and service configurations are updated.
SECURITY
FRAYMARK takes reasonable organisational and technical measures intended to protect personal information against accidental or unlawful loss, alteration, disclosure, access or misuse.
No internet-based system can be guaranteed to be completely secure, so absolute security cannot be promised.
THIRD-PARTY LINKS
The FRAYMARK website may contain links to third-party websites or services. Their privacy practices are governed by their own policies, not this Privacy Policy.
CHANGES TO THIS POLICY
This Privacy Policy may be updated when FRAYMARK's services, systems, providers or legal obligations change.
The current version will be published on this page and the "Last updated" date will be changed accordingly.
CONTACT
Questions about this Privacy Policy or the handling of your personal data can be sent to:
