Privacy Notice
This privacy notice tells you what to expect us to do with your personal information.
Last Updated: 23 July 2026
This notice is reviewed and updated from time to time. The version in force is the one published on our website. It is your responsibility to check you are relying on the current version. Where a future change is material — for example, a new category of recipient or a new purpose for processing — we will take additional steps to notify you via email communication.
1. About Us
Sexton Pendleton Limited (“we”, “our”, “us”) is the controller of your personal data.
As the data controller, we are committed to handling your personal data lawfully, fairly and transparently. If you have any questions about this notice or how we process your data, we encourage you to contact us.
Contact details:
Registered name: Sexton Pendleton Limited (registered in England and Wales with company number 16091315)
ICO reference: ZB855440
Postal address: 71-75, Shelton Street, Covent Garden, London, WC2H 9JQ
Email address: emily@emilysextoncoaching.com
Sexton Pendleton Limited (trading as Emily Sexton Coaching) is a provider of coaching and leadership development services. You must be 18 years or older to use our services.
We operate an online website emilysextoncoaching.com (and other domains emilysextoncoaching.org; emilysextoncoaching.co.uk) enabling prospective and existing clients to learn more about our services.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at emily@emilysextoncoaching.com
2. What Information We Collect, Use and Why
We collect or use the following information to provide and improve products and services for clients:
• Names and contact details
• Addresses
• Occupation
• Third party information (such as family members or other relevant parties)
• Payment details (including card or bank information for transfers and direct debits)
• Usage data (including information about how you interact with and use our website, products and services)
• Employment details (including salary, sick pay and length of service)
• Information relating to compliments or complaints
• Audio recordings (e.g. calls)
• Records of meetings and decisions
• Website user information
We do not routinely collect special category data; however, sometimes clients share this information with us as part of confidential coaching conversations. This information is subject to additional protection due to its sensitive nature. Special Category data includes:
• Personal data revealing racial or ethnic origin
• Personal data revealing political opinions
• Personal data revealing religious or philosophical beliefs
• Personal data revealing trade union membership
• Genetic data
• Biometric data (where used for identification purposes)
• Data concerning health
• Data concerning a person’s sex life
• Data concerning a person’s sexual orientation
We collect or use the following personal information for information updates or marketing purposes:
• Names and contact details
• Addresses
• Website and app user journey information
• IP addresses
We collect or use the following personal information for dealing with queries, complaints or claims:
• Names and contact details
• Correspondence
Lawful Bases & Data Protection Rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights, which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website.
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Our lawful bases for collecting or using personal information for marketing purposes are:
Legitimate interests (to promote our coaching and facilitation services to prospective clients and grow our business)
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications, and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
You can ask us to stop sending you marketing messages at any time by emailing us at emily@emilysextoncoaching.com.
If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legitimate interests (responding to and resolving queries) for non-clients, where there is no contract in place.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at emily@emilysextoncoaching.com. In case we need to use your details for an unrelated new purpose, we will let you know and explain the legal grounds for processing.
Where we are required to collect personal data by law, or under the terms of the contract between us, and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered, but if we do, we will notify you at the time.
You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which mean you may not receive all the information you ask for. Read more about the right of access.
Your Rights
You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
You have the right to ask us to delete your personal information. Read more about the right to erasure.
You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
You have the right to object to the processing of your personal data. Read more about the right to object to processing.
You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
When we use consent as our lawful basis, you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us at emily@emilysextoncoaching.com.
If you are within the UK, you can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests — in which case we will notify you within the first month and may extend the response time by up to a further two months.
3. Where We Get Personal Information From
Directly from you
Publicly available sources (e.g. social media; such as Companies House and the Electoral Register based inside or outside the UK and/or the EU)
Your employers, organisation
Third parties (partners, websites and analytics providers)
4. Automated Decision-Making
We do not use automated decision-making or profiling that produces legal effects or similarly significantly affects you. Any psychometric or 360 feedback reports we use are interpreted and applied by us as your coach; they are not used to make decisions about you without human involvement.
5. Who We Share Information With
Data processors
Reputable psychometric assessment distributors, including: 3 Minute Mile, Hogan Assessments, Lumina Learning and Edgecumbe Consulting.
These data processors collect inputs to the psychometric assessment from the client/coachee and then publish a report from the inputs/data, which is shared with us as the Coach.
You can view their Privacy Policies here:
• https://www.edgecumbe.co.uk/privacy-statement/
• https://www.hoganassessments.com/privacy-policy
• https://www.3minutemile.org/privacy-policy/
• https://luminalearning.com/general-privacy-notice/
Others we share personal information with:
Professional or legal advisors
Publicly on our website, social media or other marketing and information media
Professional consultants
Suppliers and service providers, such as:
DocuSign, a secure electronic signature platform, to manage and process electronic agreements. See their privacy policy.
TypeForm.com, a third-party platform, to collect client feedback and testimonials. When you submit feedback, an automated message is sent to us at our Microsoft Teams account to notify us of your submission and to share the content of the feedback with us. This automation is in place to streamline our processes and ensure timely review of your input. Both Typeform.com and Microsoft Teams act as Data Processors on our behalf. For more information please refer to their respective privacy policies on their websites.
Claude (Anthropic) (with training models switched off), to help us organise, summarise and draw insights from our own written notes made after coaching sessions, as well as from email correspondence and meetings.
Microsoft applications (e.g. 365, cloud storage solutions etc.), to manage our emails, store information, manage workflows and correspondence, so that we can provide a good service to you and respond to client/prospect messages promptly.
Associate organisations we work with or through to deliver certain engagements. What we share depends on the type of engagement:
For 1:1 coaching engagements, we only ever share administrative and engagement-related information with an associate organisation (such as attendance, scheduling and feedback forms). The confidential content of coaching sessions is never shared without your explicit consent, in line with our confidentiality commitments set out in our Business Terms & Conditions and Terms and Conditions for Coachee.
For group facilitation and training programmes delivered with an associate organisation (such as Presenting to Win™, delivered with Bulmer Group International), these sessions are not treated as confidential coaching. Contributions, presentations and feedback given during these sessions may be shared with the associate organisation and, where relevant, the sponsoring organisation, to support participants' development and inform reporting on the programme.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Where a recording or an AI note-taking tool is used during a session by explicit agreement of everyone taking part (for example, for a group session), that tool processes personal data under its own privacy policy, which we do not control. We encourage anyone using such a tool to review its privacy policy first.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
6. Sharing Information Outside of the UK
Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.
Organisation: Anthropic (Claude)
Category of recipient: AI productivity tool
Country: United States
Safeguard: Addendum to the EU Standard Contractual Clauses (SCCs)
Organisation: Microsoft
Category of recipient: Service Provider
Country: United States
Safeguard: Addendum to the EU Standard Contractual Clauses (SCCs) and the International Data Transfer Agreement (IDTA)
Organisation: Bulmer Group International
Category of recipient: Associate organisation
Country: Australia
Safeguard: Australia does not currently have a UK adequacy decision. Where we transfer data to an associate organisation based there, we rely on appropriate safeguards (such as contractual data protection clauses with the associate), or, where applicable, your explicit informed consent.
Where necessary, our data processors will share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.
For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.
Data may be transferred to, stored, and processed in the United States and other global locations where Microsoft or its sub-processors operate. Safeguard: The International Data Transfer Agreement (IDTA)
7. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding the correct retention period, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it, whether those purposes can be achieved by other means, and any applicable legal requirements.
As a guide: Contact, Identity, Financial and Transaction Data is retained for 6 years after you stop being a client, in line with UK tax law. Coaching records and psychometric or 360 feedback reports are retained for a shorter period following the end of an engagement, reflecting the sensitivity of that data. In some circumstances we may anonymise your personal data for research or statistical purposes, in which case we may use it indefinitely without further notice to you.
A full breakdown of retention periods by category of data is available on request. Please use the email address provided in the above contact details.
How to Complain
If you have any concerns about our use of your personal information, you can make a data protection complaint to us:
Email: emily@emilysextoncoaching.com
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
Helpline number: 0303 123 1113 Website: https://www.ico.org.uk/make-a-complaint
We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
If you are within the EU and are not happy with any aspect of how we collect and use your data, you have the right to complain to the data protection authority of the country in which you are based. We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.