Privacy Policy

The controller of the personal data described in this policy is CLIENT TO CONFIRM: registered legal entity name, registered at CLIENT TO CONFIRM: registered address.

For anything in this policy, including any of the requests described below, contact us at CLIENT TO CONFIRM: privacy contact email.

We only collect what the service actually needs. In practice that is four groups of information.

Information you give us

• Application details. Your name, email address, phone number, and the answers you give in the application form.
• Booking details. The date and time you choose, and the contact details you confirm with the calendar.
• Assessment answers. The five scores you give yourself and the three written answers on the assessment page.

Information about how you reached us

• The campaign, ad set and ad you arrived from, carried in the link as campaign parameters (utm_source, utm_medium, utm_campaign, utm_content, utm_term).
• Advertising click identifiers such as fbclid from Meta and gclid from Google, where present.
• The page you first landed on, and the site that referred you.

We keep this so that we can tell which advertising actually works. It is stored alongside your record and is not sold or shared for anyone else’s marketing.

Information collected automatically

• Your IP address and browser user-agent, recorded in ordinary server logs for security and troubleshooting.
• Your consent choice, and the time you made it, so we can show that we honoured it.

Information from advertising and analytics tools

If you allow marketing cookies, the Meta pixel sets and reads cookies in your browser (including _fbp and _fbc) so that Meta can attribute your visit to an ad. Until you allow this, we do not load those tags at all.

Under the UK GDPR and the EU GDPR, we rely on the following legal bases.

• Your consent. For marketing and advertising cookies, for sharing conversion data with Meta, and for marketing emails. You can withdraw this at any time, and withdrawing it does not affect anything we did before you withdrew it.
• Steps before a contract. For handling your application, arranging your call, and reviewing your assessment before we speak.
• Performance of a contract. For delivering coaching if you become a client.
• Our legitimate interests. For keeping the site secure, preventing abuse, and understanding at an aggregate level which advertising works.

We do not sell your personal data. We share it only with the providers that run parts of this service for us, and only with what they need.

• Our hosting provider, which serves this website.
• GoHighLevel, our CRM, which stores your contact record, your application and your assessment, and sends the emails about your call.
• Calendly, which handles your booking. Choosing a time takes place on Calendly’s own page.
• Stripe, which processes payment if you go on to join the programme. We never see or store your card details.
• Meta Platforms, if you have allowed marketing cookies. We send conversion events directly from our server as well as from your browser. Identifiers such as your email address are hashed before they are sent, so Meta receives a scrambled value rather than the address itself.

Some of these providers are based outside the UK and the EEA. Where that is the case, the transfer is covered by the UK International Data Transfer Addendum or the EU Standard Contractual Clauses, together with any additional safeguards the provider offers. The full, current list of providers is available on request.

We keep your data only as long as we have a reason to.

• Applications that do not become clients: CLIENT TO CONFIRM: retention period.
• Client records: CLIENT TO CONFIRM: retention period, plus any period we are required to keep financial records for.
• Server logs: CLIENT TO CONFIRM: retention period.

When a period ends, we delete the data or irreversibly anonymise it.

You can ask us to do any of the following, free of charge.

• Give you a copy of the personal data we hold about you.
• Correct anything that is wrong or incomplete.
• Delete your data, where we have no overriding reason to keep it.
• Restrict or object to how we use it.
• Send your data to another provider in a portable, machine-readable format.
• Withdraw consent you have given, including for marketing emails and advertising cookies.

We will respond within one month. If you are not satisfied, you can complain to the Information Commissioner’s Office at ico.org.uk in the UK, or to your national supervisory authority in the EU.

Essential cookies keep the site working and are always on. Marketing cookies stay unloaded until you allow them. The Meta pixel is not fetched at all before you say yes, rather than being loaded and then told to behave. You can change your choice at any time using Cookie settings in the footer of any page.

If we change this policy we will update the date at the top of the page. If the change materially affects how we use your data, we will tell you directly.