Privacy Policy

Hello there!

Thank you for checking out our privacy policy. At Ruth Thornton we take your privacy seriously. We’re committed to protecting your privacy and handling your information in a responsible way while you use our website and services.

We encourage you to read this policy alongside any other privacy notices we might provide, so you're fully in the loop about how and why we use your information.

Who's in charge of your data?

The controller of your data is Ruth Thornton and we can be contacted on:

Email address: ruth.marie.thornton@gmail.com.

Not happy with something?

Let’s chat and try to fix it. You've also got the right to talk to the Information Commissioner's Office (ICO) at (www.ico.gov.uk), but we hope to resolve any issues directly.

What type of data do we collect about you?

‘Personal data' is information that identifies you. If we've removed your identity (by making the data anonymous), it won’t be classed as personal data. We might collect, use, store, and share various types of personal data about you as follows:

Identity details such as first and last name, username or similar identifier, marital status and title, date of birth and gender.
Contact details such as your billing address and delivery address, email address and telephone number.
Financial information such as your bank account and payment card details.

Aggregated Data: We may also use the above information, without any of your identifiable details, to produce aggregated data. An example incudes statistical or demographic data, that can help us understand our client needs better. We may aggregate usage data to calculate the percentage of users accessing a specific website feature. If we combine this data with your personal data at any point so you do become identifiable, we treat this as personal data and use this in accordance with this policy.

Special Category Data: We do not collect any special category data about you, such as health data, information about your race, religious beliefs, sex life or sexual orientation, political opinions or trade union memberships, criminal convictions/offences, and your genetic and biometric data.

How do we collect your personal data?

We use different methods to collect data from and about you. The majority of the time, our information is collected directly when you contact us in the following ways:

When you fill in any new client onboarding forms;
When you complete any forms before or during an appointment;
Verbally during discussions;
Correspondence with us via post, phone, email or otherwise;
When you apply for our services or any of our products;
When you request marketing communications to be sent to you;
When you give us feedback or contact us.

This data collection helps us to improve user experience, and to gather information about how you use our website. For more information, please refer to our Cookie Policy, which can be accessed here.

What are the purposes for which we use your personal data?

The purposes for which we will be using your data include:

To register you as a new customer.
To provide our services and to process and deliver any orders, including: a) to manage payments, fees and charges and b) to collect and recover money owed to us.
To manage our relationship with you e.g., to notify you about changes to our terms of this privacy policy or to ask you to leave a review and/or take a survey.
To enable you to partake in a prize draw, competition or complete a survey.
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

We rely on one or more of the following lawful conditions to process your data as outlined above:

To fulfil our contract with you;
For our legitimate interests; or
To comply with legal obligations.

In some scenarios, we’ll ask for your consent, especially for collecting sensitive data. In most circumstances, generally, we do not obtain your consent for processing your personal data. If we send you marketing communications and you no longer wish to receive them, you can opt out anytime by contacting us or clicking on the ‘unsubscribe’ button on our marketing communications.

We may process your personal data for more than one lawful reason at a time, depending on the specific purpose for which we are using your data. If you’d like more information on the specific legal ground we are relying on, on occasions where we rely on more than one legal ground, please feel free to contact us.

Do we use cookies?

Cookies help make our website work better for you, remembering your preferences and improving your experience. You can control cookie settings in your browser. Cookies make your browsing experience on our site as smooth as possible, because they remember your preferences.

Our website uses cookies to distinguish you from other users of our website. Please refer to our Cookie Policy here to learn more.

Do we use third-party links?

Our website might link to third-party websites, tools and apps. Clicking on these links may allow third parties to collect or share your data.

We do not control said websites and are not responsible for said websites’ privacy policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Do we ever share your personal data?

We take your data's security seriously and only allow certain people to access it.

We may share your personal data with the parties set out below for the purposes as stated further above.

Service providers, acting as processors who provide IT and system administration services.
Professional advisers, acting as processors or joint controllers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

All of the above third parties have a requirement to respect the security of your personal data. We do not permit them to use your personal data for their own purposes – they are only permitted to process your data for specified purposes in line with our instructions.

AI usage

Artificial Intelligence (AI): AI refers to the use of computer systems, software, or applications that are designed to perform tasks that would normally require human intelligence. This includes, but is not limited to, capabilities such as learning, reasoning, problem-solving, perception, language understanding, and interaction.

We may use AI tools to assist with the provision of our services, including data analysis, drafting documents and responding to enquiries. Any AI tools we employ are used in compliance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR).

When using AI tools, we ensure:

Personal data is processed lawfully, fairly, and transparently.
Data minimisation principles are upheld, meaning we only provide AI tools with the information strictly necessary for the intended purpose.
Robust security measures are in place to protect your personal data during any processing involving AI tools.
When using AI tools, we ensure that personal data is retained only for as long as necessary to fulfil the purposes outlined in our policy, after which it is securely deleted or anonymised.

We have listed below the specific AI tools we are using within our business, the purpose, the types of data we are collecting and our legal basis for this processing.

For further enquiries on our AI usage or to exercise your rights, please contact us using the details provided in this policy.

AI tool name	Purpose	Types of data used	Legal basis for processing
Claude	To transcribe and summarise coaching sessions for client review.	Voice recordings and session transcripts (fully confidential and anonymised).	Legitimate interest
Otter AI	To develop interactive website content and create bespoke coaching resources.	Anonymised coaching themes, quiz logic, and general leadership frameworks.	Legitimate interest

AI tool name	Purpose	Types of data used	Legal basis for processing
Claude	To transcribe and summarise coaching sessions for client review.	Voice recordings and session transcripts (fully confidential and anonymised).	Legitimate interest
Otter AI	To develop interactive website content and create bespoke coaching resources.	Anonymised coaching themes, quiz logic, and general leadership frameworks.	Legitimate interest

Do we ever transfer your data internationally?

We may transfer your data outside of the United Kingdom/EEA, but only when we can be sure it is protected.

Many of our external third parties are based outside the United Kingdom/EEA and so their processing of your personal data will involve a transfer of data outside the United Kingdom.

Whenever we transfer your personal data out of the United Kingdom, we make sure it is protected by at least implementing one of the following safeguards:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the United Kingdom
Where we use certain service providers, we may use specific contracts approved by the UK Information Commissioner’s Office and the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific process used by us when transferring your personal data out of the United Kingdom.

How secure is your data with us?

We have strong security measures in place to keep your personal information safe. Only authorised individuals who have a need to know are granted access to your data, such as our employees or trusted partners. They will process your data in accordance with our confidentiality terms.

In the rare circumstances that there is a personal data breach, we have procedures in place and will notify you, along with any applicable regulator, when we’re legally required to.

What is our process for retaining your data?

We only keep your data as long as necessary for the reasons we collected it.

By law we have to keep basic information about our customers (including contact information, identity details, financial information and data relating to your transactions with us) for six years after they cease being customers for tax purposes.

For information that does not fall under the definition of basic, to determine the appropriate retention time, we look at what kind of data it is, how sensitive it is, the risks if it's misused, why we need it, and if there are other ways to achieve the same goals. We also consider applicable legal, regulatory, tax, accounting and other requirements.

What are your legal rights in relation to your data?

You have the following rights regarding your personal data:

Access: You can request a copy of the personal data we hold about you. This is known as a "data subject access request."

Correction: If the personal data we have about you is incomplete or incorrect, you can ask us to correct it.

Erasure: You can ask us to delete your personal data. It's important to note, however, that there might be legal reasons that prevent us from fulfilling this request. If such reasons exist, we will inform you when you make your request.

Objection: In certain situations, you have the right to object to the processing of your personal data.

Restriction of Processing: You can request that we restrict the processing of your personal data under specific circumstances.

Data Portability: You have the right to request the transfer of your personal data directly to you or to a third party of your choice.

Withdrawal of Consent: At any point where we rely on your consent to process your personal data, you have the right to withdraw this consent. Withdrawal of consent will not affect the legality of the processing done before the consent was withdrawn. Should you withdraw your consent, we might be unable to provide you with certain products or services. We will inform you if that is the case when you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

We won’t charge any fees for you to request access to your personal data. However, a reasonable fee may be charged if your request is clearly unjustified, repetitive or excessive. We also reserve the right to not comply in this scenario. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes and contact

We regularly review our privacy policy. Please keep us updated if your personal data changes. If you have any questions or need to exercise your rights, just get in touch.

Thanks for reading our privacy policy. If you have any questions please don't hesitate to contact us.