Bright Threads ADHD Coaching customer privacy notice

This privacy notice tells you what to expect us to do with your personal information.

• Contact details

• What information we collect, use, and why

• Lawful bases and data protection rights

• Where we get personal information from

• How long we keep information

• Who we share information with

• Sharing information outside the UK

• How to complain

Contact details

Telephone

(+44) 07448468578

Email

enquiries@brightthreadscoaching.com

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

• Payment details (including card or bank information for transfers and direct debits)

• Transaction data (including details about payments to and from you and details of products and services you have purchased)

• Usage data (including information about how you interact with and use our website, products and services)

• Information relating to compliments or complaints

• Records of meetings and decisions

• Website user information

We collect or use the following personal information for information updates or marketing purposes:

• Names and contact details

• Marketing preferences

• Purchase or account history

• Website and app user journey information

We collect or use the following personal information to protect client welfare:

• Names and contact information

• Health and wellbeing information

We also collect or use the following special category information to protect client welfare. This information is subject to additional protection due to its sensitive nature:

• Health information

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details

• Purchase or service history

• Relevant information from previous investigations

• Customer or client accounts and records

• Financial transaction information

• Correspondence

Lawful bases and 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:

• Your right of access - 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 means you may not receive all the information you ask for. Read more about the right of access.

• Your right to rectification - 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.

• Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.

• Your right to restriction of processing - 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.

• Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.

• Your right to data portability - 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.

• Your right to withdraw consent – 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 using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

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 information updates or marketing purposes 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.

Our lawful bases for collecting or using personal information to protect client welfare are:

• Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

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.

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

• We collect or use personal data such as contact details, previous correspondence and payment or service use history in order to fully answer your queries and to give context under which to investigate and respond to complaints or claims.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Where we get personal information from

• Directly from you

• From Stripe, our third-party payment processing platform.  

How long we keep information

Your personal information will be retained for as long as necessary to carry out the purpose for which it was collected.  After this time any physical and/or digital data will be destroyed securely.

• Enquiry data will be retained for one year from last contact.

• Signed coaching contracts, consent forms, terms accepted and fee agreements will be retained for 6 years after the end of the coaching relationship.

• Session notes will be retained for two years after the end of the coaching relationship, these will not contain any personal or sensitive information.

• Financial and transactional data such as invoices, receipts, payment confirmations or transaction metadata will be retained for 6 years from the end of the financial year in which the transaction occurred.

• Mailing list membership and marketing consents will be reviewed with you every 3 years so that you can decide whether to refresh your consent. Unsubscribe data will be retained for 3 years.

• Complaint files will be retained for 3 years after closure.

• Potential or actual legal claims will be retained for 6 years, or longer if legally necessary.

In order to meet the requirements of supervision and to renew accreditation with the European Mentoring and Coaching Council as an accredited coach:

• EMCC accredited coaches are required to engage in regular supervision in order to reflect upon and enhance their coaching skills and practice.  Supervision may involve discussing aspects of coaching sessions, but any information shared is fully anonymised and cannot identify you. 

• Coaching client names, email addresses, and dates/times of coaching sessions will be retained in a coaching hours log for up to 5 years.  Personal data is not included in the log when submitted to the EMCC for accreditation, but does need to be retained as evidence during the accreditation process in case of audit. After each accreditation cycle (5 years), data will be anonymised.

Who we share information with

Others we share personal information with

• Emergency services - if we believe you or someone else is at risk of harm.

• All records are securely stored in Google Workspace cloud storage.

Sharing information outside 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.

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.

Organisation name: Google Workspace

Category of recipient: Storage Provider

Country the personal information is sent to: USA

How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

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

Last updated 

30 December 2025