PRIVACY NOTICE

Last updated 22 October 2025

This privacy notice for Equity Coach LTD (‘we’, ‘us’, or ‘our’), describes how and why we might collect, store, use, and/or share (‘process’) your information when you use our services (‘Services’), such as when you:
Visit our website(s) equitycoach.co.uk, sport.equitycoach.co.uk or any website of ours that links to this privacy notice.
Engage with us in other related ways, including any commissions, sales, marketing, or events.
Questions or concerns?
Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@equitycoach.co.uk

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Disclose to Us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following: Names, phone numbers, email addresses, and contact preferences.
Special Categories of Personal Data in Course Notes, Comments & Training Sessions/Workshops.
We do not intentionally collect or process ‘Special Categories of Personal Data’ (which includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or data concerning health) via the course notes, comment sections, or any open text fields on our website(s).
While our content may involve discussions of sensitive topics, we strongly urge and require you to refrain from inputting or voicing your or anyone else’s own Special Categories of Personal Data into any course notes, comments, online training or similar. These features are designed for course and training related reflections and discussion, not for the secure storage of sensitive personal data.
In the event we become aware of any Special Categories of Personal Data that has been inadvertently provided by you in your course notes or comments, we reserve the right to immediately delete or mask such information to protect your privacy and ensure our compliance with data protection laws. By using these features, you acknowledge and accept this policy.”
Information automatically collected
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
Log and Usage Data.
Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’), and hardware settings).
Device Data.
We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data.
We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. PROCESSING INFORMATION RELATING TO INCIDENTS OR ALLEGATIONS.

In the course of our work, we may receive, document, and store information relating to alleged incidents, reports of discrimination, or other related claims. This processing is essential for the maintenance of high standards in our work, the fulfillment of our public interest mission, and to protect the vital interests of the individuals involved.
What We Collect:
The information collected may include:
Details of the incident, allegation, or claim.
The Special Categories of Personal Data (e.g., racial or ethnic origin) of the person making the report and/or the alleged perpetrator.
Details relating to the alleged perpetrator, which may constitute criminal offence data.
Testimonies, communications, and internal investigation records.
Legal Basis for Processing:
We process this sensitive data under the following legal bases:
Substantial Public Interest: Where the processing is necessary for reasons of substantial public interest (as permitted by law) and serves to prevent or tackle discrimination, or to uphold ethical and professional standards in our field.
Legal Obligation: Where necessary to comply with a legal obligation (e.g., reporting requirements or cooperation with official bodies).
Establishment, Exercise, or Defence of Legal Claims: When the data is necessary for us to establish, exercise, or defend a legal claim or prospective legal proceedings.
Data Security and Retention:
Given the highly sensitive nature of this information:
It is stored using enhanced security measures (e.g., high-level encryption and restricted access controls) to prevent unauthorized access or disclosure.
Access is strictly limited to named personnel whose role absolutely requires access to manage the incident or fulfil a legal requirement.
We will retain this incident data only for as long as is strictly necessary to resolve the matter, fulfill our legal obligations, or maintain a secure record for potential future legal claims. Once this period expires, the data will be securely deleted or anonymized.

3. HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
To respond to user inquiries/offer support to users.
We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
To send administrative information to you.
We may process your information to send you details about training and cohort sessions, our products and services, memberships, changes to our terms and policies, and other similar information.
To enable user-to-user communications.
We may process your information if you choose to use any of our offerings that allow for communication with another user.
To save or protect an individual’s vital interest.
We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

4. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
Consent.
We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
Performance of a Contract.
We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
Legal Obligations.
We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests.
We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
In legal terms, we are generally the ‘data controller’ under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. This privacy notice does not apply to the personal information we process as a ‘data processor’ on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the ‘data controller’ responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers’ privacy practices, you should read their privacy policies and direct any questions you have to them.
Our Legitimate Interests.
Where we rely on our ‘Legitimate Interests’ to process your personal data, these interests include:
Security and Fraud Prevention: To protect our Services, systems, and users from malicious or fraudulent activity.
Service Improvement and Development: To better understand how our Services are used, which features are popular, and to continuously improve the user experience and our product offerings.
Business Operations: To manage our business effectively, including financial reporting, administration, and in the context of business restructuring or sales.

5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

International Transfers
We are a UK-based company, but our third-party service providers (such as hosting providers and analytics services) may be located outside of the European Economic Area (EEA) and the UK (referred to as “third countries”).
When we transfer your personal data to these third countries, we ensure it is protected by implementing at least one of the following safeguards:
Adequacy Decision: We transfer data to countries deemed by the European Commission or the UK government to provide an adequate level of protection (e.g., the EU-U.S. Data Privacy Framework for certified US recipients)
Standard Contractual Clauses (SCCs): We implement the Standard Contractual Clauses (SCCs) approved for the UK/EU, which require recipients to adhere to European data protection standards.
Transfer Impact Assessment (TIA) Compliance: Where we rely on SCCs, we carry out a Transfer Impact Assessment (TIA) to assess, on a case-by-case basis, if the laws and practices in the recipient country ensure a level of protection essentially equivalent to that in the UK/EEA, especially regarding government access to data. If we determine that equivalent protection cannot be guaranteed, we implement supplementary technical and organisational measures (such as end-to-end encryption) or suspend the transfer.
Vendors, Consultants, and Other Third-Party Service Providers.
We may share your data with third-party vendors, service providers, contractors, or agents (‘third parties’) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:
Communication & Collaboration
Tools Data Analytics Services
Data Storage Service Providers
Finance & Accounting Tools
User Account Registration & Authentication Services
Website Hosting Service Providers
We also may need to share your personal information in the following situations:
Business Transfers.
We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

6. COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
The criteria we use to determine our retention periods for different categories of personal data include:
Duration of Relationship.
For as long as we have an ongoing relationship with you (e.g., while you maintain an account or are subscribed to our communications).
Legal Obligations.
For the period required to comply with a mandatory legal obligation, such as retaining records for tax purposes (e.g., typically 6 to 7 years in the UK).
Litigation/Disputes.
For the duration necessary to resolve a dispute or potential litigation concerning our relationship with you. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup) then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. YOUR RESPONSIBILITIES

To maintain a safe, secure, and confidential environment for all our users and participants, your adherence to the following responsibilities is required:
Account and Password Security.
You are responsible for maintaining the confidentiality of your account password and for all activities that occur under your account.
Do not share your password with anyone.
Do not use the same password for your account that you use for other online services.
Notify us immediately if you suspect any unauthorised use of your password or account.
Confidentiality in Group Training and Sessions.
Our training sessions, especially those that are live or group-based, may involve the sharing of sensitive experiences, personal data, or confidential business information by participants. To protect the privacy of others, you agree to the following:
Respect the confidentiality of all information shared by other participants or facilitators during any group training, discussion forums, or coaching sessions.
You must not record, reproduce, or distribute any part of the training content or discussions without our express written permission.You must not share with any third party the personal information, identifying details, or specific stories shared by other participants.
Breach of these responsibilities may result in the immediate suspension or termination of your account and access to our services.

10. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 years old. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@equitycoach.co.uk.

11. WHAT ARE YOUR PRIVACY RIGHTS?

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?’ below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications.
You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?’ below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
If you have questions or comments about your privacy rights, you may email us at privacy@equitycoach.co.uk.

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

13. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this privacy notice from time to time. The updated version will be indicated by an updated ‘Revised’ date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us by email at privacy@equitycoach.co.uk, or by post at:
Equity Coach LTD
5-7 Montgomery Street Lane
Edinburgh
EH7 5JT
UK

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please email privacy@equitycoach.co.uk