Privacy Policy
This policy explains how Camino Real Coaching (“we”, “us”, “our”) processes personal data when you use our website, request the free PDF, book a discovery call, email us, or otherwise deal with Andrew Considine as coach.
We process personal data in line with the EU General Data Protection Regulation (GDPR), the Irish Data Protection Act 2018, and (where it applies) the ePrivacy rules on storing information on your device.
1. Who we are (controller)
The data controller is Camino Real Coaching, operated by Andrew Considine, based in Kildare, Ireland.
Contact: Andrew@andrewconsidine.com. We do not appoint a separate Data Protection Officer; Andrew is your point of contact for all privacy requests.
This policy covers the Camino Real Coaching landing and related pages (including when they are served from pormuchosmas.com/landingtest or caminorealcoaching.com).
2. What personal data we collect
Free PDF form
If you request 7 Self-discovery steps we collect: your name, email address, and the fact that you ticked consent. We also receive a technical anti-spam field (honeypot) that humans leave empty. We do not ask for a phone number on this form.
Booking a call
If you book via Calendly we (and Calendly) may process your name, email, timezone, chosen slot, and anything you type in Calendly’s form.
Email and coaching enquiries
If you write to Andrew@andrewconsidine.com we process whatever you send (typically name, email, and your message).
Visit measurement (first-party)
To understand whether the site is used, we may store a random visitor id in your browser and send referrer domain (or “Direct”), device type (Mobile / Tablet / Desktop), and session duration to our host. We do not use this to build a marketing profile of you, and we do not sell it.
Hosting and security logs
The web server may record technical data such as IP address, date and time, requested URL, referrer and browser type. That is ordinary hosting practice: to keep the site available, diagnose faults, and investigate abuse.
This landing does not currently load Google Analytics or a Facebook pixel. Conversion hooks exist only if those scripts are added later; if that happens we will update this policy first.
3. How we use it
- Send or deliver the PDF you asked for, and notify Andrew of the request.
- Schedule and run your discovery call, and answer coaching questions.
- Keep the website working, secure, and understandable (aggregated visit counts).
- Comply with law (for example, to show we had consent, or to handle a rights request).
The PDF form consent is for sending you that PDF and notifying Andrew. It is not a separate newsletter signup. We will not add you to a marketing list from this form unless we ask for a distinct opt-in and you give it.
4. Legal bases (GDPR Article 6)
- Art. 6(1)(b) — steps at your request / contract: PDF you asked for; booking and running a call; answering an enquiry.
- Art. 6(1)(a) — consent: ticking the box on the PDF form; storing a visitor id if you have not opted out (you can withdraw below).
- Art. 6(1)(f) — legitimate interests: site security, diagnosing faults, and aggregated statistics that do not identify you in reports. You may object.
5. Who we share it with (processors)
We do not sell personal data. We use providers who act on our instructions:
- FormSubmit (formsubmit.co) — delivers the PDF form to Andrew’s email.
- Calendly — scheduling widget and booking records.
- Google (fonts.googleapis.com / fonts.gstatic.com) — webfonts. Your IP address is sent to Google when fonts load.
- Website host — today the landing may run on infrastructure operated with Por Muchos Más (Spain). If the same pages are later served from caminorealcoaching.com, the domain/hosting provider (for example Namecheap, if used) will process technical logs.
Calendly’s widget loads from Calendly’s servers when you open a booking. Their own policy applies to data they control as (sub-)processor: calendly.com/privacy.
6. International transfers
FormSubmit, Calendly and Google may process data in the United States or other countries outside the EEA. Where that happens we rely on GDPR-approved tools (typically the European Commission’s Standard Contractual Clauses) plus the provider’s safeguards. You can ask us for more detail at the email below.
7. Cookies and similar storage
We do not use a third-party ad cookie. We may use:
- localStorage key
crc_visitor_id— random id so we do not double-count the same browser. - sessionStorage — short-lived session id and start time for duration.
- localStorage key
crc_analytics_optout— remembers if you turned measurement off.
These are not strictly required to read the site. You can refuse them:
This control applies to this browser only. Clearing site data may reset it.
8. How long we keep it
- PDF requests: up to 12 months after the last contact, unless you ask us to delete sooner, or we must keep a short record of the request.
- Calendly / call correspondence: up to 24 months after the last interaction, or longer if needed for legal or accounting reasons.
- Visit measurement: aggregated counts and session records used for stats; we do not keep them longer than needed to operate the site (and we prune old operational logs in the ordinary course of hosting).
- Emails you send us: as long as the conversation is active, then up to 24 months unless a longer legal duty applies.
9. Your rights
Under the GDPR you may: access your data; correct it; erase it; restrict or object to certain processing; receive a copy (portability) where the law gives that right; and withdraw consent without affecting processing already done. Email Andrew@andrewconsidine.com. We may need to confirm it is you before we act. We will answer within one month (extendable by two months for complex requests, as the GDPR allows).
This site is not directed at anyone under 18. We do not knowingly collect children’s data. If you think we have, tell us and we will delete it.
We use appropriate technical and organisational measures (HTTPS, access limited to Andrew and hosting operators who need it). No internet transmission is perfectly secure.
10. Contact and complaints
Privacy requests: Andrew@andrewconsidine.com.
You may complain to the Data Protection Commission (Ireland) — www.dataprotection.ie — or to your local EU supervisory authority. We would appreciate the chance to put things right first.
We may update this page. The date at the top is the version that applies. Continued use of the site after a change means the new version applies to later visits; it does not take away rights you already have.