Privacy Notice

Last Updated: 29 May 2025

1.   INTRODUCTION  

This privacy notice provides you with details of how we collect and process your personal data through your use of our website emilysextoncoaching.com (and other domains emilysextoncoaching.org; emilysextoncoaching.co.uk)

By providing us with your data, you warrant to us that you are over 13 years of age.

Sexton Pendleton Limited (trading as “Emily Sexton Coaching” and using the website/domains above) is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Our website is hosted by Squarespace, a third-party service provider that processes personal data on our behalf under a data processing agreement (here). Squarespace acts as a Data Processor under our instruction and is committed to complying with applicable data protection laws. They implement appropriate technical and organisational measures to safeguard your personal data. For more information you can view Squarespace’s privacy policy here: https://www.squarespace.com/privacy

Contact Details

Our full details are:

Full name of legal entity: Sexton Pendleton Limited

Postal address: 71-75, Shelton Street, Covent Garden, London, WC2H 9JQ

Email address: emily@emilysextoncoaching.com

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 DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT 

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

  • Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

  • Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

  • User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

  • Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

  • Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

  • Psychometric assessment data we may collect and process psychometric assessment data such as 360 degree feedback to provide coaching services and establish tailored development goals. This data is processed as part of fulfilling our contractual obligations to you and, where necessary, with your explicit consent. The data is used solely for the purposes outlined at the time of collection and is handled in according with applicable data protection laws.

Sensitive Data

While we do not intentionally collect sensitive personal data through our website, during course of providing coaching services and/or psychometric assessment data as part of our contractual obligations/agreed services, clients may choose to disclose sensitive data to us. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Any such, data disclosed will be processed in accordance with appropriate data processing laws and we will ensure that appropriate safeguards are in place to protect this data.

Where required, we will obtain explicit consent for the processing of sensitive personal data.

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.

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.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

3.  HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails or disclosing information verbally during coaching sessions). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this our Cookie Policy

We may receive data from third parties such as analytics providers such as Google based outside the UK and/or the EU, advertising networks such as Facebook based outside the UK and/or the EU, such as search information providers such as Google based outside the UK and/or the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside or outside the UK and/or the EU.

We may receive data from third parties with whom we partner to deliver psychometric assessments such as Hogan assessments and 360 feedback reports. Our primary providers for these purposes Edgecumbe Consulting Group and Hogan Assessments. You can see their privacy and cookie policies on their websites.

4. MARKETING COMMUNICATIONS 

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to 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 or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by emailing us at emily@emilysextoncoaching.com at any time.

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. 

5.  DISCLOSURES OF YOUR PERSONAL DATA  

  We may have to share your personal data with the parties set out below:

  • Service providers who provide IT and system administration services.

  • Professional advisers including lawyers, bankers, auditors and insurers

  • Government bodies that require us to report processing activities.

  • Psychometric assessment and reporting providers/partners, including Edgcumbe Consulting Group, and Hogan assessments.

  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6.  INTERNATIONAL TRANSFERS  

We are subject to the provisions of the UK General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the UK, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data.

7.  DATA SECURITY  & THIRD PARTY SERVICE PROVIDERS

We use third-party service providers to facilitate certain aspects of our business operations and take care to ensure your personal data is not accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

For example, we use DocuSign, a secure electronic signature platform, to manage and process electronic agreements. DocuSign may process personal data such as names, email addresses, and signatures as part of this service. For more information on how DocuSign handles personal data, please refer to their privacy policy.

We use 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.

We use Edgecumbe Consulting Group Limited, a third-party that provides reporting and psychometric assessments such as, but not limited to, 360 degree feedback assessments/reports. Edgecumbe acts as a Data Processor under our instruction under a Data Processing Agreement and is committed to complying with applicable data protection laws. They implement appropriate technical and organisational measures to safeguard your personal data and will not use your personal data for any other purpose. For more information, see Edgecumbe’s Privacy Statement.

We also partner with 3 Minute Mile and Hogan Assessments, third-party service providers that processes data on our behalf and in accordance with GDPR. You can view their Privacy Policies here: https://www.hoganassessments.com/privacy-policy

https://www.3minutemile.org/privacy-policy/

8.  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 what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.  YOUR LEGAL RIGHTS  

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

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/ If you wish to exercise any of the rights set out above, please email us at emily@emilysextoncoaching.com

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 you 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 this case, we will notify you.

If you are within the UK and are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). 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.

10. THIRD-PARTY LINKS  

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.

11. COOKIES  

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