Last updated [date].

This notice explains what personal information I collect, why I collect it, how I look after it and what your rights are. I have tried to keep it short and plain. If anything is unclear, please ask.

Who I am

SMARTer Entrepreneurs is the trading name of Simon Hale, a sole trader providing coaching and mentoring to owners and leadership teams of businesses that sell expertise. I am the "controller" of your personal information, which means I decide how it is used and I am responsible for looking after it.

Contact: Simon Hale, SMARTer Entrepreneurs, [business address]. Email: [email address].

ICO registration: [registration number].

What I collect

Contact details: your name, job title, business name, email address, phone number and business address.

Enquiries and bookings: what you tell me when you get in touch, book a Discovery Call or take an online assessment or review, including your answers.

Coaching and mentoring records: session notes, goals, action plans, progress reviews and the information you share about yourself and your business during our work together.

Business information: financial and other business information you choose to share, such as key numbers, plans and team structure.

Billing information: what I need to invoice you and keep accounts. I do not store card details.

Marketing preferences: whether you have asked to receive my newsletter or updates.

Website information: my website uses cookies and similar technology. You can control these through the cookie banner on the site.

Coaching conversations can sometimes touch on personal matters, such as health or family circumstances. I avoid recording this kind of information unless it is needed for our work and you have agreed. If I do record it, I keep it to the minimum and treat it with extra care.

Why I use it, and the legal basis

Replying to enquiries and arranging Discovery Calls. Legitimate interests: responding to people who contact me.

Delivering coaching and mentoring, keeping notes and tracking progress. Contract: to provide the service you have agreed to.

Invoicing and keeping accounts. Contract, and legal obligation to keep tax records.

Sending my newsletter or updates. Consent, which you can withdraw at any time.

Occasional relevant updates to business contacts I already work with. Legitimate interests, with an easy way to opt out in every message.

Professional supervision, without your name or your business's name. Legitimate interests: maintaining the quality and ethics of my practice.

Dealing with questions, complaints or legal claims. Legitimate interests and legal obligation.

Recording sensitive personal information, where needed for our work. Your explicit consent.

I do not use your information for automated decision-making or profiling.

Who I share it with

I do not sell your information or share it for anyone else's marketing. I share it only where I need to:

Service providers: the tools that help me run the practice, such as video calls, email, file storage, booking, accounting and my website. They process information only on my instructions and under contract. My current providers are Wix (website, booking and forms), Zoom (video calls) and Google (email and file storage).

AI tools: I may use AI tools to help with things like scheduling, reminders and preparation. I will not put information that identifies you or your business into any tool that does not meet the confidentiality and security standards in my client agreement. I will tell you which tools I use if you ask.

Supervision: I discuss my work with a professional supervisor, without your name or your business's name.

Specialists: only with your permission, for example when you ask me to help brief your accountant or an employment adviser.

Sponsors: where your business pays for your coaching, only what has been agreed in writing by you, the business and me.

When the law requires it: for example to HMRC, or where there is a serious risk of harm. Wherever it is lawful and safe, I will tell you first.

Where your information is stored

Your information is stored in the UK or the European Economic Area where possible. Some of my service providers may store or access information in other countries, such as the United States. Where they do, I make sure appropriate safeguards are in place, as UK data protection law requires.

How long I keep it

Coaching and mentoring records: six years after our work ends, in case of questions or claims, then securely deleted.

Invoices and accounting records: as long as the law requires for tax purposes, then securely deleted.

Enquiries that do not lead to work together: two years from last contact.

Assessment and review responses: two years, unless they become part of our work together.

Newsletter and marketing preferences: until you unsubscribe, then only a record that you have opted out.

How I keep it safe

I keep your information in password-protected, access-controlled systems with two-factor authentication where available. Paper notes, if any, are stored securely and shredded when no longer needed. Only I have access to your coaching records.

Your rights

You have the right to:

• ask for a copy of the personal information I hold about you

• ask me to correct information that is wrong or incomplete

• ask me to delete your information, where I have no good reason to keep it

• ask me to restrict how I use your information, or object to my using it

• ask for information you gave me in a format you can pass to someone else

• withdraw consent at any time, where I rely on it, without affecting anything done before

To use any of these rights, email me at [email address]. I will respond within one month. There is normally no charge.

Complaints

If you are unhappy with how I have handled your information, please tell me first and I will try to put it right. You also have the right to complain to the Information Commissioner's Office (ICO), the UK regulator for data protection, at ico.org.uk or on 0303 123 1113.

Changes to this notice

I review this notice regularly and will update it if the way I use personal information changes. The date at the top shows when it was last updated.