Privacy Policy
How Camino Coaching Ltd collects, uses, and protects your personal information under UK data protection law.
Draft Notice (Pending Final Approval): This privacy notice is a structured placeholder prepared for review and confirmation by Craig Muirhead and legal counsel before final publication. Bracketed fields (company number, registered office address, processor list, and retention periods) require Craig's sign-off.
1. Who We Are (Data Controller)
The data controller responsible for your personal data on caminocoaching.co.uk is Camino Coaching Ltd.
- Company Name: Camino Coaching Ltd
- Company Number: [PLACEHOLDER: Company number to be confirmed by Craig]
- Registered Office: [PLACEHOLDER: Registered office address to be confirmed by Craig]
- Privacy & Data Enquiries: [email protected] or via our Contact page.
2. What Personal Data We Collect
We only collect personal data that you choose to give us or that is strictly necessary to operate and protect the site:
- Race Weekend Review & Assessment Requests (
/request,/request-driver): Your first name, email address, selected discipline/audience (Rider, Driver, Funded, or Executive), and optional campaign referral parameters (UTM tags). - Contact Form Enquiries (
/contact): Your name, email address, discipline category (Rider, Driver or karter, or Other), message content, page source, and browser user-agent string. - Academy Sign-In (
/login): Your email address when requesting a magic sign-in link to access existing training. - Spam & Bot Verification (Cloudflare Turnstile): When you use our contact form, Cloudflare Turnstile checks technical request signals to verify that the submission comes from a real person rather than an automated bot.
- Website Analytics (Consent-Gated Only): If (and only if) you explicitly opt in through our analytics consent banner, we use Google Analytics 4 (GA4) to measure page views (
page_view) and aggregate form completion counts (generate_leadwith discipline category, andcontact_submit). We never send your name, email address, or message text to analytics.
3. Purpose and Lawful Basis for Processing
Under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, we rely on the following lawful bases:
- Delivering your Review & Free Training: When you request a Race Weekend Review, Podium Contenders Blueprint, or Executive Assessment, we process your name and email to send your private diagnostic link and associated training materials (Lawful basis: steps taken at your request prior to entering into a contract, consent, and legitimate interests). You can unsubscribe from training emails at any time using the link in every email.
- Responding to Contact Enquiries: When you send a message via
/contact, we use your details to reply to your question (Lawful basis: legitimate interests in responding to enquiries, or pre-contractual steps). Contact form messages are not added to marketing sequences. - Account Access: Processing your email on
/loginto send your training access link (Lawful basis: performance of a contract). - Security & Abuse Prevention: Using Cloudflare Turnstile and server-side validation to protect our forms from spam and automated attacks (Lawful basis: legitimate interests in securing our services).
- Analytics & Site Improvement: Loading GA4 cookies/scripts only after you click "Accept analytics" on our consent banner (Lawful basis: explicit consent under PECR and UK GDPR Article 6(1)(a)).
4. Processors and Service Providers
We share personal data only with trusted service providers (data processors) who act on our instructions under data protection agreements. We never sell your personal data.
- Cloudflare, Inc.: Edge website hosting (Cloudflare Pages) and Cloudflare Turnstile spam protection on the contact form.
- Resend: Transactional email delivery service used to route
/contactenquiries to our team inbox ([email protected]). - Supabase: Database hosting used to store
/contactenquiry records securely with Row Level Security enabled. - Google (Google Analytics 4): Anonymous/pseudonymous website measurement, loaded strictly after opt-in consent.
- Assessment, Email & CRM Platforms: [PLACEHOLDER: Craig to confirm the exact assessment, email, and CRM tools in active use, e.g. Airtable, Typeform, In The Zone App, and email service provider].
Where any processor handles data outside the UK or European Economic Area, we rely on the UK International Data Transfer Agreement (IDTA), the UK Addendum to the EU Standard Contractual Clauses, or a UK adequacy decision.
5. Data Retention
[PLACEHOLDER: Final retention schedule to be confirmed by Craig]
- Contact Enquiries: Retained in our inbox and database for as long as needed to handle your enquiry and for up to [PLACEHOLDER: e.g. 24 months] afterwards for audit and follow-up reference, unless you request earlier deletion.
- Review & Training Requests: Retained while you engage with your diagnostic results and training emails, or until you unsubscribe or request erasure.
- Client Coaching Records: Retained for the duration of our coaching relationship and for up to [PLACEHOLDER: e.g. 6–7 years] where required for UK tax, accounting, or legal compliance.
6. Cookies, Local Storage, and Analytics Consent
By default, this website sets no analytics or advertising cookies. We use browser localStorage only to remember your chosen motorsport discipline (camino-discipline) and your analytics consent preference (camino_analytics_consent).
You can change or withdraw your analytics consent at any time using the buttons below:
7. Your Rights Under UK GDPR
Under UK data protection law, you have the right to:
- Request access to a copy of the personal data we hold about you.
- Request correction of inaccurate or incomplete personal data.
- Request erasure ("right to be forgotten") of your personal data where there is no lawful reason for us to keep it.
- Object to processing based on legitimate interests, or request restriction of processing.
- Request data portability where applicable.
- Withdraw consent at any time where processing is based on consent (such as marketing emails or analytics).
To exercise any of these rights, email us at [email protected] or use our Contact form.
8. How to Complain (ICO)
If you have any concerns about how we handle your personal data, please contact us first at [email protected] so we can resolve it promptly.
You also have the right to lodge a complaint with the UK supervisory authority, the Information Commissioner's Office (ICO):
- Website: https://ico.org.uk/make-a-complaint/
- Telephone: 0303 123 1113
- Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF