1. Who I am

This privacy notice explains how I collect, use, store and protect personal information.

I am Gary Rankin, a sole trader trading as Gary Rankin Coaching.

For the purposes of UK data protection law, I am the data controller. This means I decide why and how personal information is processed.

You can contact me at:

Email: [email protected]

This notice applies to my websites, application pages, enquiry and consultation process, private coaching services and related communications.

2. The personal information I collect

Depending on how you interact with me, I may collect:

Your name, email address, telephone number and other contact details.

Information submitted through a private coaching application.

Information about your work, business, current circumstances, goals, challenges, readiness for coaching and preferred coaching partnership.

Emails, WhatsApp messages, voice notes and other communications between us.

Notes made during consultations and coaching sessions.

Paper coaching notes, which are normally identified using only a client’s first name.

Appointment, consultation and coaching history.

Payment and transaction information.

Information required for invoices, accounting and tax records.

Technical information generated when you use my website or application pages, which may include your IP address, device, browser, timestamps, pages visited and form activity.

Any other information you choose to provide.

Stripe processes card payments on my behalf. I do not normally receive or store your complete card details.

3. How I collect your information

I collect personal information directly from you when you:

Complete a coaching application.

Contact me by email, WhatsApp, telephone or another communication channel.

Arrange or attend a consultation.

Enter into a coaching partnership with me.

Make a payment.

Subscribe separately to receive marketing communications.

Otherwise interact with my websites, services or communications.

Some technical information may be collected automatically by the platforms used to operate my websites, forms and communications.

4. How and why I use your information

I use personal information to:

Review coaching applications.

Understand your circumstances, goals and reasons for applying.

Decide whether I believe a consultation or coaching partnership may be suitable.

Contact you about your application or enquiry.

Arrange and conduct consultations.

Provide private coaching services.

Communicate with you between sessions.

Process payments and maintain financial records.

Administer my business and maintain accurate records.

Protect the security and proper operation of my websites, forms and systems.

Respond to complaints, disputes, legal claims or regulatory enquiries.

Comply with legal, tax, accounting and regulatory obligations.

Improve my services and application process.

Send marketing communications where you have separately consented or where the law otherwise permits me to do so.

5. My lawful bases for processing

Under UK data protection law, I must have a lawful basis for using personal information.

I generally rely on the following bases:

Steps before entering into a contract

When you apply for coaching, request information, arrange a consultation or ask me to consider working with you, processing your information is necessary to take steps at your request before potentially entering into a coaching agreement.

Performance of a contract

Where you become a client, I process information as necessary to provide the coaching services we have agreed, administer the partnership, communicate with you and process payments.

Legitimate interests

I may process information where necessary for my legitimate business interests, provided those interests are not overridden by your rights and freedoms.

These interests include:

Reviewing and responding to genuine applications and enquiries.

Operating and improving my business.

Maintaining appropriate business records.

Protecting the security of my systems and services.

Preventing misuse or fraud.

Managing complaints and protecting or defending legal rights.

Legal obligations

I process information where necessary to meet legal, accounting, tax or regulatory obligations.

Consent

Where I rely on your consent, including for certain marketing communications, you may withdraw that consent at any time.

Submitting a coaching application does not automatically add you to a general marketing list.

6. Sensitive personal information

My coaching application does not deliberately ask you to provide medical diagnoses, detailed health information or other categories of particularly sensitive personal information.

Please avoid including information about your health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetics, biometrics, sex life or sexual orientation unless it is directly relevant and you are comfortable sharing it.

Where you voluntarily include sensitive personal information, I will only use it to the minimum extent reasonably necessary to understand and respond to your application or enquiry.

Where an additional legal condition or explicit consent is required before I can use that information further, I may ask you to provide that consent separately. Where there is no appropriate reason or legal basis to retain or use it, I may disregard or securely delete it.

Coaching is not medical treatment, psychotherapy, psychiatric care or emergency support.

7. Who I share personal information with

I do not sell personal information.

I may share or make information accessible to trusted service providers where necessary to operate my business and provide my services.

These currently include:

Easy Peasy Business, including its underlying HighLevel systems, for website hosting, forms, application management, customer relationship management and workflow automation.

Google Workspace for email, document storage and business administration.

Google Meet for online consultations and coaching sessions.

WhatsApp, operated by Meta, for messages and voice-note communication.

Stripe for payment processing.

Professional advisers such as accountants, insurers, solicitors or technology support providers where reasonably necessary.

Government bodies, regulators, law-enforcement agencies or courts where disclosure is legally required or necessary to protect legal rights.

Service providers may process information only for the purposes for which they have been engaged, subject to their contractual and legal responsibilities.

8. International transfers

Some service providers may store or process personal information outside the United Kingdom, including in the United States or European Economic Area.

Where personal information is transferred internationally, I take reasonable steps to ensure that an appropriate legal safeguard is used. This may include UK adequacy regulations, approved contractual protections or another safeguard permitted under UK data protection law.

You can contact me for further information about the safeguards relevant to your information.

9. How long I keep information

I keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including legal, accounting, tax, insurance and dispute-resolution purposes.

My normal retention periods are:

Unsuccessful or incomplete coaching applications

Applications that do not lead to a coaching partnership will normally be retained for up to 12 months after the application decision or our last meaningful contact.

This allows me to administer the application, respond if you contact me again, maintain an appropriate record of the decision and address any complaint or dispute.

At the end of that period, the application will normally be deleted or anonymised unless there is a clear legal or business reason to retain it for longer.

Retention of an application does not mean that I will use it to send general marketing communications without an appropriate lawful basis.

Client and coaching records

Information relating to a coaching partnership may normally be retained for up to six years after the partnership ends, where reasonably necessary for business administration, insurance, tax, contractual or legal purposes.

Coaching notes that are no longer required may be securely destroyed sooner.

Financial records

Invoices, payment records and information required for tax purposes will be retained for the period required by HM Revenue & Customs and other applicable laws.

Marketing information

Where you have separately subscribed to marketing, I may retain your contact details until you unsubscribe or withdraw your consent. I may retain a minimal suppression record after you unsubscribe to ensure that I respect your preference.

Retention periods may be extended where information is required for an ongoing complaint, legal claim, regulatory matter or legal obligation.

10. Security

I take reasonable physical, organisational and technical steps to protect personal information against loss, misuse, unauthorised access, alteration or disclosure.

These measures include, where appropriate:

Password-protected accounts and devices.

Access controls and authentication measures.

Reputable cloud and payment-service providers.

Limiting access to those who genuinely require it.

Keeping paper coaching notes in a locked office.

Identifying paper notes using only a client’s first name where practicable.

Securely deleting electronic information and destroying paper records when they are no longer required.

No internet, email, messaging or storage system can be guaranteed to be completely secure. You should therefore avoid sending information that is not reasonably necessary.

11. Cookies and technical information

My application funnel may use cookies or similar technologies that are necessary for security, form functionality, navigation and remembering progress through an application.

Easy Peasy Business and its underlying systems may also create limited technical and usage records about visits, page interactions and form submissions.

I do not currently use Google Analytics, Meta Pixel or third-party advertising pixels on this application funnel.

If I introduce non-essential analytics or advertising cookies in future, I will update this notice and request consent where required before using them.

You can control or delete cookies through your browser settings, although disabling essential cookies may prevent parts of the website or application from working correctly.

12. Marketing communications

Submitting a coaching application or contacting me does not automatically subscribe you to newsletters or general promotional emails.

I will contact you as reasonably necessary to respond to your application, arrange a consultation, administer a coaching partnership or deal with another request you have made.

I will only send separate marketing communications where:

You have consented to receive them; or

Another lawful permission applies.

You may unsubscribe from marketing at any time by using the unsubscribe link in an email or contacting me at [email protected].

13. Automated decision-making

I do not use solely automated decision-making to accept or reject private coaching applications.

Applications are reviewed personally by me.

14. Your data protection rights

Depending on the circumstances and the lawful basis being used, you may have the right to:

Request access to the personal information I hold about you.

Ask me to correct inaccurate or incomplete information.

Ask me to erase your information.

Ask me to restrict how your information is used.

Object to certain processing, including processing based on legitimate interests.

Receive certain information in a portable format.

Withdraw consent where processing is based on consent.

Complain to the Information Commissioner’s Office.

These rights are not absolute and may be subject to legal exceptions.

15. Your right to object

You have the right to object to processing based on legitimate interests.

I will consider your objection and stop the processing unless I have compelling legitimate grounds to continue or the information is required for the establishment, exercise or defence of legal claims.

You may object to direct marketing at any time.

16. How to exercise your rights

To exercise a data protection right or ask a question about your information, contact:

Gary Rankin
Email: [email protected]

I may need to request information to confirm your identity before responding.

17. Complaints

Please contact me first if you have a concern about how your information has been handled, so that I have an opportunity to investigate and resolve it.

You also have the right to complain to the UK data protection regulator:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113
Website: www.ico.org.uk

18. Children

My private coaching application and services are not directed at children under the age of 18.

Please do not submit personal information through the application if you are under 18.

19. Changes to this notice

I may update this privacy notice where my services, systems, legal responsibilities or use of personal information changes.

The latest version will be published on this page with the updated date shown above.