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PRIVACY POLICY

Policy version: 5th May 2026

Introduction

This Privacy Policy is provided by Laura Unwin (trading as Laura Unwin, Coaching & Consultancy), (‘we’, ‘our’ or ‘us’) for use of our services including our website (Services).

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).

It also explains your rights in relation to your personal data and how to contact the relevant regulator or us in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

  1. What this policy applies to

    This privacy policy relates to your use of the Services only.

    The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information, see the section ‘Who we share your personal data with’ below.

  2. Personal data we collect about you

    3. The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:


    Category of data

    In more detail

    Identity data you input into the Services

    Registration is mandatory in order to use the Services

    • Your name and email address;

    • Your phone number;

    • Employer, job title or occupation; and

    • Other contact details you provide to us.

    Enquiry and Booking Data

    • information you provide in enquiry forms;

    • correspondence with us by email, phone, social media or otherwise;

    • discovery call details;

    • booking information; and

    • appointment history.

    Coaching and client relationship data

    • information you choose to share with us in connection with coaching;

    • notes of coaching sessions;

    • goals, actions, reflections and progress records;

    • attendance records;

    • records of decisions, emails, calls or messages; and

    • information relating to compliments, concerns or complaints.

    Payment and transaction data

    • billing information;

    • bank payment details relevant to BACS payments;

    • transaction information;

    • subscription status; and

    • limited payment-related information provided to us by payment providers.

    We do not store your full payment card details on our own systems.

    Data collected when you use specific functions in the Services

    Data you store online with us using the Services including your usage history or preferences (while such data may not always be personal data as defined by law in all cases we will assume it is and treat it in accordance with this policy as if it were)

    Other data the Services collect automatically when you use them

    • Your activities on, and use of, the Services which reveal your preferences, interests or manner of use of the Services and the times of use

    • Other information such as device type, IMEI numbers, MAC address of networks, other unique device identification, device operating system, mobile network information, app version number, storage usage, data usage, time zone settings, etc.

    Data collected when you make an enquiry with us

    Your name and email address

    If you do not provide personal data we ask for where it is required, including the geo-localisation services, it may prevent us from providing services and/or the Services to you.

    We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

  3. Sensitive Data

    4. In the course of providing coaching services, you may choose to share more sensitive personal data with us, including information about your health, wellbeing, racial or ethnic origin, religious beliefs or other sensitive matters (Special Category Personal Data).

    We do not ask for more Special Category Personal Data than is reasonably necessary for the provision of the Services. Where we process Special Category Personal Data, we will do so only where we have identified:

    1. an appropriate lawful basis under Article 6 of the UK GDPR; and

    2. an additional condition for processing under Article 9 of the UK GDPR,

      3. as required by applicable data protection law.

    Depending on the circumstances, the Article 6 lawful basis may include:

    1. that the processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract;

    2. that the processing is necessary for our legitimate interests, where those interests are not overridden by your rights and interests; or

    3. where appropriate, your consent.

    Depending on the circumstances, the Article 9 condition may include your explicit consent, or another condition permitted by applicable law.

    If you do not want us to process Special Category Personal Data about you, please avoid sharing that information with us. However, in some circumstances this may affect our ability to tailor the Services appropriately to your needs.

  4. How your personal data is collected

    5. We collect personal data from you directly when you sign up to the Services, contact us directly or reach out to us via social media, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services.

    We use cookies and similar technologies that are necessary for the Website to function and to process orders. We may also use analytics or marketing cookies if enabled. For details, please see our Cookie Policy here. Where required, we will ask for your consent before setting non-essential cookies.

  5. How and why we use your personal data

    6. Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

    1. where you have given consent

    2. to comply with our legal and regulatory obligations

    3. for the performance of a contract with you or to take steps at your request before entering into a contract, or

    4. for our legitimate interests or those of a third party

    A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

    The table below explains what we use your personal data for and why.

    What we use your personal data for

    Our reasons

    Providing services and/or the functionalities of the Services to you

    Depending on the circumstances:

    • to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services)

    Responding to enquiries and arranging discovery calls or bookings

    Depending on the circumstances:

    • to take steps at your request before entering into a contract; and/or

    • for our legitimate interests in managing enquiries and running our business efficiently

    Providing coaching services and related support

    Depending on the circumstances:

    • to perform our contract with you; and/or

    • where appropriate, for our legitimate interests in administering and improving our professional services

    Managing subscriptions, membership content and service administration

    Depending on the circumstances:

    • to perform our contract with you;

    • to take steps at your request before entering into a contract; and/or

    • for our legitimate interests in operating and administering the Services

    Processing payments, issuing invoices and maintaining financial records

    Depending on the circumstances:

    • to perform our contract with you; and/or

    • to comply with our legal obligations, including accounting and tax obligations

    To enforce legal rights or defend or undertake legal proceedings

    Depending on the circumstances:

    • to comply with our legal and regulatory obligations

    • in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others

    Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or service or other important notices

    Depending on the circumstances:

    • to comply with our legal and regulatory obligations

    • in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you

    Protect the security of systems and data

    To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

    Operational reasons, such as improving efficiency, training, and quality control or to provide support to you

    For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you

    Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, and offerings or other efficiency measures

    For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app

    Updating and enhancing user records



    Depending on the circumstances:

    • to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services)

    • to comply with our legal and regulatory obligations

    • where neither of the above applies, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services

    To comply with our legal and regulatory obligations


    Depending on the circumstances:

    • to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services)

    • to comply with our legal and regulatory obligations

    where neither of the above applies, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services

    To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency.

    In such cases information will be anonymised where possible and only shared where necessary

    Depending on the circumstances:

    • to comply with our legal and regulatory obligations

    • in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets


    See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

  6. Marketing

    7. We intend to send you email marketing to inform you of our services such as promotions.

    We will always ask you for your consent before sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up with us and you did not do so.

    You will have the right to opt out of receiving marketing communications at any time by:

    We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

    For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

  7. Who we share your personal data with

    8. We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, including developers, cloud storage providers, cloud-based team communication and workspace platforms, payment processors, email marketing platforms, customer relationship management tools, customer support software, logistics and shipping partners, survey and feedback tools, advertising and retargeting networks, analytics providers, professional advisers (such as our accountant) and legal and regulatory authorities.

    We only allow service providers to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to you and to us.

    We or the third parties mentioned above may occasionally also need to share your personal data with:

    If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

    We will not share your personal data with any other third party.

  8. How long your personal data will be kept

    9. We will keep your personal data only for as long as is reasonably necessary for the purposes for which it was collected, including to provide the Services, comply with legal, tax, accounting or regulatory obligations, maintain appropriate business records, and establish, exercise or defend legal claims.

    As a general guide:

    1. enquiry data is usually retained for up to 12 months after our last meaningful contact with you, unless there is a reason to keep it for longer (for example, where you become a client or there is an ongoing issue or dispute);

    2. coaching records, session notes and related client file records are typically retained for 6 years after the end of the client relationship;

    3. marketing data is retained until you unsubscribe, withdraw your consent, or otherwise ask us to stop using your personal data for marketing purposes;

    4. financial, invoicing and transaction records are retained for as long as required by applicable tax, accounting and legal requirements; and

    5. technical logs, website security data and similar operational records are retained for as long as reasonably necessary for security, audit, troubleshooting and business continuity purposes.

    We may retain personal data for longer where this is reasonably necessary to establish, exercise or defend legal claims, deal with complaints, comply with legal obligations, or protect our legitimate business interests.

    Where it is no longer necessary for us to retain your personal data, we will delete it or anonymise it.

  9. Transferring your personal data out of the UK

    10. At this point in time, we do transfer your personal data outside of the UK where service providers or their servers are located outside the UK. We comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. Any updated destinations to which we send your personal data, would be indicated in the present section and notified to you in accordance with the section on ‘Change to this privacy policy’ below.

    Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:

    In the event we could not or choose not to continue to rely on either of those mechanisms at any time, we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.

  10. Your rights

    11. You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here .


    Access to a copy of your personal data

    The right to be provided with a copy of your personal data.

    Correction (also known as rectification)

    The right to require us to correct any mistakes in your personal data.

    Erasure (also known as the right to be forgotten)

    The right to require us to delete your personal data—in certain situations.

    Restriction of use

    The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.

    Data portability

    The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.

    To object to the use

    The right to object:

    • at any time to your personal data being used for direct marketing (including profiling)

    • in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests.


    Not to be subject to decisions without human involvement

    The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

    We do not make any such decisions based on data collected by the Services. The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

    We do not make any such decisions based on data collected by the Services.


    For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

    If you would like to exercise any of those rights, please complete a request form—available on our website at https://lauraunwin.com/#contact or email, see below: ‘How to contact us’. When contacting us please:

  11. Keeping your personal data secure

    12. We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

    We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

    If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org . Get Safe Online is supported by HM Government and leading businesses.

  12. How to complain

    13. Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

    You also have the right to lodge a complaint with the Information Commissioner.

    The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

  13. Changes to this privacy policy

    14. We may change this privacy policy from time to time. When we make significant changes, we will take steps to inform you, for example, via the Services or by other means, such as email.

  14. How to contact us

    15. You can contact us by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

    Our contact details are shown below: