1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.evokeandlead.com.

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

Evoke & Lead Coaching Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details

Our full details are:

Full name of legal entity: Evoke & Lead Coaching Ltd

Email address: [email protected]

Postal address: 167–169 Great Portland Street, 5th Floor, London, W1W 5PF

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 [email protected].

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

This 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, website chat or any other communication that you send us.

We process this data for the purposes of communicating with you, responding to enquiries about our coaching services, programmes, membership, events or other services, 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

This includes data relating to any purchases of goods and/or services such as your name, title, billing address, email address, phone number, contact details, purchase details, booking details and payment information.

Payments are currently processed through Stripe. We do not directly store your full payment card details.

We process this data to supply the goods and/or services you have purchased, manage your bookings and participation in our services, process payments and refunds where applicable, communicate with you about your purchase and 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

This 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

This includes data about your use of our website and online services such as your IP address, your login data where applicable, 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 may include our website systems, analytics tools and cookie technologies where these are enabled and, where required, you have provided the appropriate consent.

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 to understand the effectiveness of our marketing.

Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer and protect our website and our business, understand how our services are used, grow our business and decide our marketing strategy. Where consent is required for the use of cookies or similar technologies, we will obtain your consent before those technologies are used.

Marketing Data

This includes data about your preferences in receiving marketing from us and your communication preferences.

This may include information provided when you subscribe to our newsletter, request a free resource, join a waitlist, request information about our services, register an interest in a programme or membership, or otherwise choose to receive communications from us.

We process this data to send relevant information about our services, programmes, membership, resources, events and other Evoke & Lead Coaching Ltd updates, and to understand the effectiveness of our marketing.

Our lawful ground for this processing is either consent, contract or our legitimate interests which in this case are to understand how customers use our products and services, develop them, grow our business and decide our marketing strategy.

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and, where applicable, advertisements to you and to measure or understand the effectiveness of the advertising or marketing we provide.

Our lawful ground for this processing is our legitimate interests which is to grow our business. Where applicable law requires consent, including for certain cookies or electronic marketing activities, we will obtain that consent.

We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests, namely to grow our business or for direct marketing, where permitted by law.

We may also use Communication Data, Customer Data, User Data, Technical Data and Marketing Data 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 establish, pursue or defend legal claims.

Coaching Data

This includes personal data collected or created when you enquire about, participate in or receive coaching services from Evoke & Lead Coaching Ltd.

Depending on the service you receive, Coaching Data may include coaching questionnaires, goals, reflections, session notes, action plans, correspondence relating to your coaching, session recordings, automatically generated Zoom transcripts and handwritten working notes.

We may record coaching sessions for professional learning, reflection and quality assurance and, where applicable, to support accurate note-taking. Clients may request a copy of their session recording while it is retained by us. Where sessions are recorded, this will be communicated to you and recordings will be made with your knowledge and agreement.

Where Zoom transcription is used, the transcript is used to assist with note-taking and the preparation of coaching records or action plans. Transcripts are deleted once they are no longer required for this purpose.

Handwritten working notes may also be taken during coaching. These are securely destroyed once our work is complete or once the relevant information has been transferred into the appropriate client record and the paper notes are no longer required.

We process Coaching Data to provide the coaching services you have purchased, maintain appropriate records of our work together, provide agreed action plans, support professional reflection and learning, and manage our contractual relationship with you.

Our lawful ground for processing this data is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract. Where Coaching Data contains special category personal data, the additional requirements described under Sensitive Data, Criminal Conviction Data and Automated Processing below will also apply.

Required Processing

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

Purposes of Processing

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 [email protected].

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.

Sensitive Data, Criminal Conviction Data and Automated Processing

During coaching, you may voluntarily share information that is classed as special category personal data under UK data protection law.

Special category data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information and genetic and biometric data.

Evoke & Lead Coaching Ltd does not routinely request special category data as part of its general website, marketing or enquiry processes. However, because coaching conversations are personal in nature, you may choose to disclose information about matters such as your physical or mental health, disability, neurodiversity, pregnancy, wellbeing, trauma or other personal circumstances where these are relevant to your coaching.

Where we process special category personal data, we will only do so where we have both a lawful basis under Article 6 UK GDPR and an appropriate condition for processing special category data under Article 9 UK GDPR. Where required, this may include obtaining your explicit consent.

We take additional care when handling this information and only retain it where it is relevant and necessary for the provision of our services, our record-keeping obligations or the establishment, exercise or defence of legal claims.

We do not routinely collect information about criminal convictions and offences.

Automated decision making

We do not carry out solely automated decision making or profiling that produces legal or similarly significant effects on you.

Automated Decision-Making (Non-Significant Decisions)

We may use automated systems and software to assist with administrative and operational tasks within Evoke & Lead Coaching Ltd.

This may include systems used to:

manage bookings and appointments;

send automated confirmations, reminders or follow-up communications;

manage newsletter subscriptions and communication preferences;

organise customer and membership records;

analyse general website or marketing trends; and

support the administration and improvement of our services.

We may also use automated transcription within Zoom to assist with preparing accurate coaching notes and action plans. The transcript itself is not used to make decisions about you.

These automated processes do not have a legal or similarly significant effect on you and do not determine whether you can access our coaching services, programmes or membership.

Where appropriate, human oversight is applied to these processes.

Automated Decision-Making (Significant Decisions)

Evoke & Lead Coaching Ltd does not currently use solely automated decision-making processes to make decisions about you that have a legal or similarly significant effect.

If this changes in the future, we will update this privacy notice before implementing such processing and provide you with information about:

the nature of the automated decision;

the personal data involved;

the logic and criteria used;

the possible consequences for you; and

the safeguards and rights available to you.

Where the law applies, these rights may include the right to request human intervention, express your point of view and challenge the decision.

If you have questions about automated processing, please contact us at [email protected].

3. HOW WE COLLECT YOUR PERSONAL DATA

We may collect personal data directly from you when you:

complete a form on our website;

contact us by email, telephone, website chat or social media;

book a discovery call;

enquire about coaching or another Evoke & Lead service;

purchase coaching, a programme, workbook or other service;

subscribe to our newsletter;

request a free resource;

join a membership or membership waitlist;

complete a coaching questionnaire;

participate in a coaching session;

provide feedback or a testimonial; or

otherwise communicate or engage with Evoke & Lead Coaching Ltd.

We may automatically collect certain Technical Data about you when you use our website through cookies and similar technologies.

Where consent is required for non-essential cookies or similar technologies, we will obtain this through our cookie consent system before those technologies are activated.

Please see our Cookie Policy for more details:

Cookie Policy

We may also receive personal data from third parties that help us operate and deliver our services. These may include:

Go High Level, which we use for our website, customer relationship management, forms, bookings and marketing automation;

Stripe, which processes payments;

Microsoft 365, which we use for business email and related administration;

Zoom, which we use to provide online coaching sessions and, where applicable, session recordings and transcription;

Cookiebot, which we use to manage website cookie consent;

analytics or website service providers where these tools are enabled;

social media platforms where you choose to communicate with us through those services; and

referral sources where someone has referred you to Evoke & Lead Coaching Ltd with your knowledge or where it is otherwise lawful for us to receive your information.

We may receive limited personal data from publicly available sources, such as Companies House, where this is relevant to a legitimate business purpose.

We do not purchase lists of personal data from data brokers for direct marketing purposes.

4. MARKETING COMMUNICATIONS

Our lawful ground for processing your personal data to send you marketing communications is either your consent or, where permitted by law, our legitimate interests, including our legitimate interest in promoting and growing Evoke & Lead Coaching Ltd.

Marketing communications may include information about our:

newsletter;

coaching services and programmes;

membership;

events and workshops;

free resources;

new products or services; and

other Evoke & Lead content or opportunities we believe may be relevant to you.

Under the Privacy and Electronic Communications Regulations (PECR), we may send you marketing communications where you have agreed to receive them or where another lawful exception applies.

Where the PECR "soft opt-in" applies, we may send marketing about our own similar products or services to customers whose contact details we obtained during a sale or negotiations for a sale, provided that we gave them a clear opportunity to opt out when their details were collected and in every subsequent marketing communication.

Where you have specifically subscribed to our newsletter or opted in to receive marketing communications, we will rely on the preferences you selected when you provided your details.

Before we share your personal data with any third party for that third party's own marketing purposes, we will obtain your express consent.

We do not sell your personal data for marketing purposes.

You can ask us to stop sending you marketing communications at any time by:

following the unsubscribe or opt-out link contained in any marketing email we send you; or

emailing [email protected].

If you opt out of receiving marketing communications, this does not affect personal data we process for other purposes, such as providing coaching services, managing purchases, maintaining financial records or meeting our legal obligations.

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, website, customer relationship management, booking, email, cloud storage, payment processing, video conferencing, transcription, cookie management, analytics and marketing administration services.

This currently includes providers such as Go High Level, Stripe, Microsoft 365, Zoom and Cookiebot where their services are used in connection with your interaction with Evoke & Lead Coaching Ltd.

Professional advisers including lawyers, bankers, accountants, auditors and insurers who provide professional services to us.

HM Revenue & Customs, regulators, courts, government bodies and other authorities that require us to report processing activities or disclose information in accordance with the law.

Contractors or specialist providers supporting Evoke & Lead Coaching Ltd where access to personal data is necessary for them to provide their services and appropriate confidentiality and data protection arrangements are in place.

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

We require third parties that process personal data on our behalf to respect the security and confidentiality of your personal data and to process it in accordance with applicable data protection law.

Where a third party acts as our processor, we only permit them to process 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 Regulation (UK GDPR) and other applicable UK data protection legislation that protect your personal data.

Some of the service providers used by Evoke & Lead Coaching Ltd operate internationally or may process personal data outside the United Kingdom. This may include providers such as Go High Level, Stripe, Microsoft and Zoom.

Where we transfer your personal data to a third party outside the UK, we will ensure that the transfer is made lawfully and that an appropriate level of protection is provided.

As such:

We may transfer your personal data to countries or territories that are covered by UK adequacy regulations and are recognised as providing an adequate level of protection for personal data; or

where we use a US-based provider that participates in the UK Extension to the EU-US Data Privacy Framework, also referred to as the UK-US Data Bridge, and the relevant transfer falls within that certification, we may rely on that adequacy arrangement; or

where an adequacy arrangement does not apply, we may use an appropriate safeguard recognised under UK data protection law, including the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, together with any required transfer risk assessment; or

we may rely on another lawful transfer mechanism or exception permitted under UK data protection legislation where appropriate.

If none of the usual transfer mechanisms or safeguards is available and the law permits us to rely on your explicit consent for a particular transfer, we will explain the risks of that transfer to you before obtaining your consent.

Where consent is relied upon, you have the right to withdraw that consent at any time.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed without authorisation.

These measures include the use of password-protected devices and business accounts, multi-factor authentication where available, secure cloud-based systems, appropriate software and security updates, secure payment processing and restricted access to personal data.

We also allow access to your personal data only to those employees, contractors, professional advisers or service providers who have a legitimate business need to know such data. Where they process personal data on our behalf, they are required to process it in accordance with our instructions, maintain confidentiality and comply with applicable data protection law.

Where handwritten working notes are taken during coaching, they are kept securely and are destroyed once our work is complete or once the relevant information has been transferred into the appropriate client record and the paper notes are no longer required.

Where Zoom transcription is used to support coaching note-taking and the preparation of action plans, transcripts are deleted once they are no longer required for that purpose.

We have procedures in place to deal with any suspected personal data breach and will investigate any suspected breach appropriately. We will notify you and the Information Commissioner’s Office or any other applicable regulator where we are legally required to do so.

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, insurance or reporting requirements.

When deciding how long to retain personal data, we consider its amount, nature and sensitivity, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process the data, whether those purposes can be achieved by other means and any applicable legal requirements.

Our typical retention periods include:

Website enquiries and discovery call information where no client relationship is established: up to 12 months.

Coaching agreements and core client records: generally retained for up to 7 years after the coaching relationship ends where this is necessary for business, insurance or legal purposes.

Client action plans: retained for up to 12 months after the coaching relationship ends.

Coaching session recordings: retained for up to 12 months after the coaching relationship ends, unless an earlier deletion is appropriate or a longer period is required for a lawful reason.

Zoom-generated transcripts: deleted once the relevant coaching notes or action plans have been completed and the transcript is no longer required.

Handwritten working notes: securely destroyed once our work is complete or once relevant information has been transferred into the appropriate client record and the original notes are no longer required.

Marketing information: retained until you unsubscribe, withdraw your consent where consent is relied upon, or the information is no longer required for the purpose for which it was collected.

Testimonials: retained while they remain relevant and, where consent is relied upon, until that consent is withdrawn.

Financial, accounting and transaction records: retained for at least six years from the end of the company financial year to which they relate, or for longer where applicable law requires us to do so.

We maintain an internal retention schedule to help ensure personal data is reviewed and securely deleted or destroyed when it is no longer required.

In some circumstances we may anonymise your personal data for research, statistical or business analysis purposes. Where information has been genuinely anonymised so that it can no longer identify you, we may use that 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 and transfer of your personal data, the right to object to processing, the right to data portability where applicable and, where the lawful ground of processing is consent, the right to withdraw your consent.

You can see more information about these rights on the Information Commissioner’s Office website:

https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/

If you wish to exercise any of the rights set out above, please email us at [email protected].

You will not normally have to pay a fee to access your personal data or to exercise any of your other rights. However, where permitted by law, we may charge a reasonable fee or refuse to comply with a request if it is manifestly unfounded or excessive.

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 exercise any of your other rights.

This is a security measure to ensure personal data is not disclosed to anyone who has no right to receive it.

We may also contact you to ask for further information or clarification where this is reasonably required in order for us to respond to your request.

When responding to a request to access your personal data, we are required to carry out searches that are reasonable and proportionate in the circumstances, as recognised by the Data (Use and Access) Act 2025.

This means we may take into account factors such as the nature of the information requested, the context in which it is held, the difficulty involved in locating it and the potential benefit to you of receiving it.

We try to respond to all legitimate requests within one month of receiving the request.

Where we reasonably require clarification from you in order to respond to a subject access request, the applicable response period may be paused while we wait for that clarification, in accordance with the Data (Use and Access) Act 2025.

Occasionally it may take us longer than one month if your request is particularly complex or you have made a number of requests. Where the law permits us to extend the response period, we may extend it by up to a further two months.

We will notify you within the initial response period if an extension is required and explain the reason for the extension.

10. HOW TO COMPLAIN

If you have a complaint about how we handle your personal data, we ask that you contact us first so that we can try to resolve it for you.

You can submit a data protection complaint to us by:

completing our online complaints form at: Submit a complaint

emailing us at [email protected]

or writing to us at:

Evoke & Lead Coaching Ltd
167–169 Great Portland Street
5th Floor
London
W1W 5PF

We will acknowledge your complaint within 30 days of receiving it.

We will investigate your complaint without undue delay, take appropriate steps to address the issues raised, keep you informed of our progress where appropriate and communicate the outcome to you clearly with sufficient detail for you to understand how we reached our conclusion.

If you are not satisfied with our response, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection matters.

Further information is available at:

www.ico.org.uk

11. 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, security or data processing practices.

When you leave our website, we encourage you to read the privacy notice of every website you visit.

12. COOKIES

Our website uses cookies and similar technologies.

Some cookies are strictly necessary for our website to operate. Other cookies may be used for purposes such as analytics, functionality or understanding how visitors interact with our website.

Where consent is required by law, non-essential cookies will not be placed on your device unless and until you have provided the relevant consent.

We use Cookiebot to help manage cookie consent and preferences on our website.

You can use our cookie consent tool to accept, reject or change your preferences for non-essential cookies.

You can also 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 certain cookies, please note that some parts of our website may become inaccessible or may not function properly.

For further information about the cookies we use, why we use them and how you can control them, please see our Cookie Policy:

COOKIE POLICY