How your data is handled.

Who I am

This policy covers the website at https://www.richardballantynemw.co.uk and the exam coaching platform at https://app.richardballantynemw.co.uk (the “Coaching Platform”). Both are run by Richard Ballantyne MW, trading as a sole trader, who is the data controller for the personal data described below.

Contact: richard@richardballantynemw.co.uk

What I collect and why

Coaching Platform students

When you register, I collect the information you provide at sign-up: your name, email address, and eligibility details such as your MW student status or your WSET Diploma (or equivalent) and trade experience. I also hold the essays, tasting notes and documents you submit, the feedback and readiness bands I return to you, and your progress history.

I use this information to provide the coaching you have signed up for: reviewing your work, preparing your feedback, charting your progress, and managing your account. The lawful basis is the performance of my contract with you.

Your submissions are reviewed and your feedback is prepared by Richard Ballantyne MW before it is sent to you. No decisions about you are made by automated means alone.

Anonymised research (only with your consent)

When you register, you can choose whether to allow your work to be included in anonymised research into common strengths and weaknesses across all students, which may be published in summary form. Nothing is ever attributed to you or published in a way that identifies you. The lawful basis is your consent, and you can withdraw it at any time by emailing me; withdrawing consent does not affect your coaching.

Payments

Subscriptions and one-off payments are processed by Stripe. I never see or store your full card details; Stripe handles them under its own privacy policy (https://stripe.com/privacy). I keep records of what you bought, your subscription status and your transaction history, for accounting, tax and support purposes. The lawful bases are the performance of my contract with you and my legal obligations as a business.

Emails

Account and service emails (welcome messages, submission confirmations, feedback notifications, receipts) are sent through Brevo. See Brevo’s privacy policy at https://www.brevo.com/legal/privacypolicy/.

If you contact me

If you email me or use the contact form, I use your name, email address and message to reply to you. The lawful basis is my legitimate interest in responding to enquiries.

Website visitors

I use Google Analytics to understand how visitors use the website, such as which pages are read and how people arrive. This relies on cookies, which are only set with your consent.

Who your data is shared with

I do not sell your data or share it with anyone for marketing. Your work is never shared with other students or published.

To run the service, I use trusted service providers who process data on my behalf and only under my instructions:

• hosting providers for the website and the Coaching Platform (Hosting UK and Heroku);
• Stripe, for payments;
• Brevo, for email delivery;
• technology service providers that help me store, process and review submissions.

International transfers

Some of these providers process data outside the UK, including in the United States. Where they do, the transfer is covered by appropriate safeguards, such as the UK International Data Transfer Addendum, standard contractual clauses, or the UK Extension to the EU-US Data Privacy Framework.

How long I keep your data

Your account, submissions, feedback and progress history are kept while your account is active and for 2 years after your last activity, then deleted or anonymised. Payment and accounting records are kept for 6 years, as UK tax law requires. Anonymised research findings contain no personal data and may be kept indefinitely. Contact enquiries are kept for as long as needed to deal with them.

Cookies

The Coaching Platform uses essential cookies to keep you signed in and to keep your account secure. These are strictly necessary for the service to work and do not track you across other websites. When you log out, your login cookies are removed.

Your rights

Under UK data protection law, you have the right to:

• access the personal data I hold about you, and receive a copy of it;
• have inaccurate data corrected;
• have your data deleted, except where I must keep it for legal, tax or accounting reasons;
• restrict or object to how your data is used;
• receive your data in a portable format;
• withdraw your consent to anonymised research at any time.

To make a request, email richard@richardballantynemw.co.uk. I will respond within one month.

If you are unhappy with how your data has been handled, you can complain to the Information Commissioner’s Office (ICO) at https://ico.org.uk. I would appreciate the chance to put things right first, so please contact me before going to the ICO.

Changes to this policy

If I make significant changes to this policy, I will update the date at the top and let registered students know by email.