CLEAR COURSE COACHING: Privacy Policy
1. WHO WE ARE AND HOW TO CONTACT US
Clear Course Coaching is a sole trader business operated by Luca Grant-Snow, trading as ‘Clear Course Coaching’. We are the data controller responsible for the personal data we collect and process about you.
If you have any questions about this Privacy Policy or how we handle your data, please contact us:
Website: www.clearcoursecoaching.co.uk
Postal address: Apartment 36, 42 Mighell Street, Brighton BN2 0AU
We are committed to protecting your personal data in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. For clients located in the European Union, we also recognise our obligations under the EU General Data Protection Regulation (EU GDPR). For clients in other jurisdictions, please see Section 14.
2. WHAT PERSONAL DATA WE COLLECT
Depending on how you interact with us, we may collect and process the following categories of personal data:
2.1 Data You Provide Directly
Contact information: name, email address, phone number;
Professional information: employment history, CV contents, qualifications, career history;
Payment information: processed securely through our payment provider — we do not store full payment card details;
Communications: emails, messages, or notes shared with us during the coaching process;
Booking information: service purchased, session date, and relevant notes.
2.2 Data Collected Automatically
Website usage data: IP address, browser type, pages visited, and time spent on our site (collected via cookies — see Section 9);
Device information: device type and operating system where relevant;
Log and usage data: diagnostic and performance information our website may collect automatically, including date/time of visits and pages viewed.
2.3 Special Category Data
We do not seek to collect special category data (such as information about health, ethnicity, religion, or disability) as a matter of course. If such information is shared with us voluntarily — for example, where it is relevant to your job search or coaching needs — we will handle it with heightened care and will only process it with your explicit consent or where otherwise permitted by law.
3. HOW WE USE YOUR PERSONAL DATA
We use your personal data for the following purposes:
To deliver the Services you have purchased, including preparing written feedback, conducting sessions, and communicating with you;
To process payments and maintain financial records;
To communicate with you about your booking, including confirmations, reminders, and follow-ups;
To improve our services, based on feedback you provide;
To comply with legal obligations, including tax and accounting requirements;
To send you marketing communications (only where you have given consent — see Section 5).
4. OUR LEGAL BASIS FOR PROCESSING
Under UK GDPR (and, where applicable, EU GDPR), we rely on the following lawful bases for processing your data:
Contract: processing is necessary to perform the contract between us (i.e., to deliver the Services you have purchased).
Legitimate interests: we may process some data on the basis of our legitimate business interests — for example, maintaining records, improving our services, and communicating with you about your experience.
Legal obligation: certain processing is required to comply with applicable laws, including financial record-keeping obligations.
Consent: for marketing communications, we will only contact you where you have given clear, affirmative consent.
If you are located in Canada, we may also process your information where you have given express or implied consent, or where we are permitted to do so under applicable Canadian law including PIPEDA.
5. MARKETING COMMUNICATIONS
We may, with your consent, contact you by email with information about our services, resources, or offers that we think may be relevant to you. You can withdraw your consent at any time by clicking ‘unsubscribe’ in any marketing email or by contacting us directly.
We will never sell or share your contact details with third parties for their marketing purposes.
6. SHARING YOUR DATA
We do not sell your personal data. We may share it with third parties only in the following circumstances:
Service providers: we use third-party platforms to support our business, including our booking and payment platform, email service provider, and document storage. These providers act as data processors on our behalf and are bound by appropriate data protection agreements.
Legal compliance: where required by law, a court order, or regulatory authority.
Business transfer: in the unlikely event that our business is sold or transferred, your data may form part of the assets transferred. You will be notified in advance.
7. HOW LONG WE KEEP YOUR DATA
We will retain your personal data for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting obligations.
Client records and financial data: retained for a minimum of 6 years from the end of the tax year in which the relevant service was delivered, in line with HMRC requirements.
Session notes and coaching materials: retained for up to 2 years after your last engagement with us, after which they will be securely deleted.
Marketing consent records: retained until consent is withdrawn.
8. YOUR RIGHTS
You have the following rights in relation to your personal data. To exercise any of these rights, please contact us using the details in Section 1, or see Section 16 for how to submit a formal Data Subject Access Request. We will respond to all valid requests within one calendar month.
Right of access: you may request a copy of the personal data we hold about you.
Right to rectification: you may ask us to correct any inaccurate or incomplete data.
Right to erasure: in certain circumstances, you may ask us to delete your personal data.
Right to restriction: you may ask us to restrict how we process your data in certain circumstances.
Right to data portability: where processing is based on consent or contract and carried out by automated means, you may request a copy of your data in a machine-readable format.
Right to object: you may object to processing based on legitimate interests, including direct marketing.
Right to withdraw consent: where processing is based on consent, you may withdraw it at any time.
Right not to be subject to automated decision-making: we do not make decisions about you using solely automated processing that would produce legal or similarly significant effects.
If you are unhappy with how we have handled your data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk or by calling 0303 123 1113.
If you are located in the EU, you may also contact your local data protection authority. A list of EU supervisory authorities is available at ec.europa.eu/justice/data-protection/bodies/authorities/.
9. COOKIES
Our website uses cookies — small text files placed on your device — to improve your browsing experience and to help us understand how our website is used. We use both strictly necessary cookies (required for the website to function) and analytical cookies (to understand visitor behaviour).
You can manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of our website.
A full Cookie Policy, including a breakdown of the specific cookies we use and how to control them, is available at www.clearcoursecoaching.co.uk/cookies.
10. DATA SECURITY
We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against accidental loss, unauthorised access, use, alteration, or disclosure. This includes use of secure, password-protected systems and encrypted communications where applicable.
While we take every reasonable precaution, no system is completely secure. If you have any concerns about the security of your data, please contact us immediately.
11. THIRD-PARTY LINKS
Our website may contain links to third-party websites. This Privacy Policy applies only to our website and services. We are not responsible for the privacy practices or content of any third-party sites and encourage you to review their privacy policies independently.
12. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we do, we will update the effective date at the top of this document and post the revised policy on our website. Where changes are significant, we will notify active clients by email.
Your continued use of our Services following any update constitutes your acknowledgement of the revised policy.
13. DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems include a Do-Not-Track (‘DNT’) feature or setting which, when activated, sends a request to websites asking that your browsing activity not be tracked. At this time, there is no universally agreed technical standard for recognising or honouring DNT signals, and we do not currently alter our data collection practices in response to them.
If a recognised standard is adopted in the future that we are required to follow, we will update this Policy accordingly.
14. INTERNATIONAL CLIENTS AND DATA TRANSFERS
14.1 If you are located in the European Economic Area (EEA)
Our business is based in the United Kingdom. Following the UK’s departure from the EU, the UK and EU operate separate but closely aligned data protection frameworks. The UK has received an adequacy decision from the European Commission, which means that transfers of personal data from the EU to the UK are recognised as providing an adequate level of protection.
Where we process your data as a client based in the EU, we do so in accordance with the EU General Data Protection Regulation (EU GDPR). Your rights under this Policy apply in full. If you believe we have processed your data in breach of EU GDPR, you may lodge a complaint with your local supervisory data protection authority.
14.2 If you are located in Canada
If you are a Canadian resident, we handle your personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and any applicable provincial privacy legislation. You have the right to access, correct, and withdraw consent to the processing of your personal data. To exercise these rights, please contact us using the details in Section 1.
14.3 If you are located in the United States or elsewhere
If you access our Services from the United States or any other jurisdiction outside the UK and EU, please be aware that your personal data will be transferred to and processed in the United Kingdom. The UK may have different data protection laws from those in your country of residence.
By using our Services, you acknowledge this transfer and consent to your data being processed in the UK in accordance with this Privacy Policy. We will handle your data with the same care regardless of where you are located.
15. CHILDREN AND MINORS
Our Services are intended solely for individuals aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18. By using our Services, you represent that you are at least 18 years of age.
If we become aware that we have inadvertently collected personal data from a person under 18, we will take prompt steps to delete that information from our records. If you believe we may hold data relating to a minor, please contact us at luca@clearcoursecoaching.co.uk.
16. DATA SUBJECT ACCESS REQUESTS (DSAR)
You have the right to request access to, details about, or a copy of the personal data we hold about you at any time. To submit a formal Data Subject Access Request, please email us at luca@clearcoursecoaching.co.uk with the subject line: ‘Data Subject Access Request’.
Please include your full name and the email address associated with your account or booking. We will verify your identity before processing your request and will respond within one calendar month of receipt.
There is no charge for making a DSAR. We reserve the right to charge a reasonable administrative fee, or to decline to act, if requests are manifestly unfounded, repetitive, or excessive.
Clear Course Coaching
www.clearcoursecoaching.co.uk | luca@clearcoursecoaching.co.uk
These documents were last reviewed in June 2026. Please consult a qualified legal professional if you have specific questions about your rights or obligations under these Terms.