Privacy Policy

PN MANAGEMENT CONSULTANT LIMITED, trading as The Focus Books, respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains what information we collect, why we collect it, how we use it, who we may share it with, how long we keep it, and your rights.

For UK data protection purposes, PN MANAGEMENT CONSULTANT LIMITED is the data controller of the personal information described in this policy.

Company: PN MANAGEMENT CONSULTANT LIMITED
Company number: 08018807
Trading name: The Focus Books
Registered office: 8 Old Forge Court, Colchester Road, Elmstead, Colchester, England, CO7 7EA
Email: mrnikam@thefocusbooks.com

1. Information we may collect

Depending on how you interact with us, we may collect:

• your name;
• email address;
• information you provide through the F.O.C.U.S. Score questionnaire;
• booking and appointment information;
• information you provide before or during coaching or consulting sessions;
• programme participation and progress information;
• feedback and testimonials where you choose to provide them;
• payment and transaction information;
• correspondence between you and us; and
• technical information relating to use of our website where this is collected by our website or service providers.

We do not directly store your full payment-card details. Payments are processed by our payment provider.

We do not intentionally request medical, clinical or other sensitive information through the F.O.C.U.S. Score.

2. The F.O.C.U.S. Score

Our website may allow you to complete the 60-Second F.O.C.U.S. Score.

Your answers are used to calculate a score and provide a personalised result or programme recommendation.

The F.O.C.U.S. Score is a self-reflection, coaching and professional-development tool. It is not a medical, psychological, clinical or diagnostic assessment.

The result is intended to help you understand patterns relating to attention, focus and working behaviour.

The scoring process may automatically assign a result based on the answers you provide. This does not make decisions about your legal rights, employment, credit, healthcare or other matters having legal or similarly significant effects.

3. Why we use your information

We may use personal information to:

• provide your F.O.C.U.S. Score and personalised result;
• respond to enquiries;
• arrange complimentary F.O.C.U.S. Diagnostic sessions;
• process purchases;
• provide F.O.C.U.S. Breakthrough™, F.O.C.U.S. Reset™ and F.O.C.U.S. Performance Mastery™ programmes;
• arrange coaching or consulting sessions;
• communicate with you about your programme;
• maintain appropriate client and business records;
• monitor programme delivery and progress;
• provide customer service;
• manage payments, refunds and accounting;
• protect our website and business from misuse or fraud;
• comply with legal, regulatory, tax and accounting obligations;
• improve our services using appropriate aggregated or non-identifying information; and
• send marketing communications where permitted by law.

4. Our lawful bases

Depending on the activity, we may rely on:

Contract — where processing is necessary to provide a service or programme you have purchased or requested.

Legal obligation — where we must retain or process information to comply with tax, accounting or other legal requirements.

Legitimate interests — where reasonably necessary to operate, administer, protect and improve our business and services, provided those interests do not override your rights.

Consent — where we specifically ask for your consent, for example for certain marketing activities or use of a testimonial.

We do not rely on consent where another lawful basis is more appropriate.

5. Payments

Payments for our programmes may be processed through an independent third-party payment provider.

The payment provider processes payment information under its own privacy and security arrangements.

We may receive information such as:

• your name;
• email address;
• amount paid;
• product or programme purchased;
• payment status; and
• transaction reference.

We do not receive or store your full payment-card number.

6. Appointment scheduling and remote service delivery

We may use third-party technology providers to support appointment scheduling, calendar management, online meetings, communications and delivery of our services.

Where you book or attend a session, information necessary to arrange and provide the service may be processed through those providers.

This may include:

• your name;
• email address;
• appointment date and time;
• meeting or session information;
• technical information required to provide the service; and
• communications connected with the booking or session.

Third-party providers may process information in accordance with their own privacy terms and, where they act on our behalf, under appropriate contractual and data-protection arrangements.

We may change technology providers from time to time without changing the nature of the services we provide.

7. Service providers

We may use trusted third-party providers to operate our business, including providers of:

• website hosting and website technology;
• questionnaire and form services;
• payment processing;
• appointment scheduling;
• remote meeting technology;
• email;
• cloud storage;
• accounting;
• IT and security services; and
• other operational technology.

These providers may process personal information only where necessary to provide their services to us or in accordance with their own lawful responsibilities.

We do not sell your personal information to advertisers or data brokers.

8. International processing

Some of our technology providers may process or store information outside the United Kingdom.

Where a transfer is subject to UK international-transfer rules, appropriate mechanisms may include UK adequacy regulations or legally recognised safeguards.

9. How long we keep information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected and to meet legal or business requirements.

As a general approach:

Financial and transaction records: normally retained for the period required by applicable tax and accounting laws.

Client programme records and coaching administration: retained for a reasonable period after your programme ends where necessary for administration, record-keeping, dispute management or legitimate business purposes.

Enquiries and F.O.C.U.S. Score information: retained only for as long as reasonably useful for responding to you, providing the requested service and managing our relationship.

Marketing information: retained until you unsubscribe, withdraw consent where applicable, or we determine that it is no longer appropriate to retain it.

We may retain information for longer where required by law, to establish or defend legal claims, or where another legitimate reason applies.

10. Purchases, cancellations and refunds

Where you purchase a service, we may process information necessary to administer the contract, including payment status, cancellations, rescheduling, refunds, disputes and customer-service correspondence.

Our contractual cancellation and refund terms are set out separately in our Terms and Conditions and Cancellation & Refund Policy.

Nothing in this Privacy Policy affects any statutory rights you may have under applicable consumer law.

11. Coaching and client notes

During a paid programme, we may keep limited working notes relating to:

• your objectives;
• agreed actions;
• focus challenges discussed;
• programme progress;
• session dates;
• follow-up actions; and
• outcomes.

These records are used to deliver and administer the programme.

We aim to collect only information that is relevant to providing the service.

12. Marketing

We may occasionally send information about relevant services, books, programmes or resources where permitted by law.

Where consent is required, we will seek it.

You may unsubscribe from marketing communications at any time by using an unsubscribe option where provided or by contacting:

mrnikam@thefocusbooks.com

Stopping marketing messages does not prevent us from sending necessary communications relating to a service you have purchased or booked.

13. Testimonials and case studies

We will not knowingly publish an identifiable testimonial, client story or case study without appropriate permission.

Where you give permission, we will use the information only in accordance with the scope of that permission.

You may contact us if you have questions about how a testimonial is being used.

14. Security

We take reasonable organisational and technical measures to protect personal information against:

• unauthorised access;
• loss;
• misuse;
• alteration;
• disclosure; and
• destruction.

No internet-based system can be guaranteed to be completely secure, but we take reasonable steps appropriate to the nature of the information we process.

15. Your data protection rights

Depending on the circumstances, UK data protection law may give you rights including:

• the right to be informed about how your information is used;
• the right to request access to your personal information;
• the right to request correction of inaccurate information;
• the right to request deletion in certain circumstances;
• the right to request restriction of processing in certain circumstances;
• the right to object to certain processing;
• the right to data portability where applicable;
• rights relating to certain forms of automated decision-making; and
• the right to withdraw consent where processing is based on consent.

These rights are subject to legal conditions and exemptions.

To exercise a privacy right, contact:

mrnikam@thefocusbooks.com

We may need to verify your identity before responding to a request.

16. Complaints

If you have concerns about how we use your personal information, please contact us first:

mrnikam@thefocusbooks.com

You also have the right to complain to the UK supervisory authority:

Information Commissioner's Office (ICO).

17. Cookies and website technologies

Our website and third-party services may use cookies or similar technologies necessary to provide website functionality.

Where non-essential cookies, analytics or similar technologies requiring consent are used, appropriate information and consent mechanisms should be provided.

A separate Cookie Notice provides additional information about these technologies.

18. Links to other websites

Our website may contain links to independent third-party services, including payment providers, booking providers, book retailers and other websites.

We are not responsible for the privacy practices of independent third-party websites.

You should review their privacy information when using their services.

19. Children

Our services are primarily intended for adults and professional-development purposes.

We do not knowingly use our website to intentionally collect personal information from children for marketing purposes.

If we become aware that personal information has been collected inappropriately, we will take reasonable steps to address it.

20. Changes to this Privacy Policy

We may update this Privacy Policy to reflect:

• changes to our services;
• changes to technology providers;
• changes to our business details;
• changes to applicable law; or
• regulatory guidance.

The latest version will be published on our website with an updated date.

21. Contact us

For privacy questions or requests:

PN MANAGEMENT CONSULTANT LIMITED
Trading as The Focus Books

Company number: 08018807

Registered office:
8 Old Forge Court
Colchester Road
Elmstead
Colchester
England
CO7 7EA

Email:
mrnikam@thefocusbooks.com