Privacy Policy

Updated 21 Sept 2026

Here is the fully updated privacy policy reflecting your current virtual assistant details, your coaching contact email for the ICO, and the 2026 UK data access standards (the statutory "reasonable and proportionate" search rule, the "stop-the-clock" clarification mechanism, and the formal internal complaint-handling mandate under the Data (Use and Access) Act).

PRIVACY POLICY

Thank you for trusting us with some information about you. We take that trust seriously and we want you to know how we use your information and why.

WHO IS HOLDING YOUR INFORMATION?

  • Name: HANNAH DESMOND ADHD COACH

  • Address: Office 15346, 182-184 High Street North, East Ham, London, E6 2JA

  • Data Retention Period(s): We retain personal data only for as long as necessary to respond to enquiries, deliver services, and meet legal, accounting, or regulatory requirements. Typically, enquiry data is retained for up to 12 months unless a client relationship is established, in which case data may be retained for up to 6 years for legal and tax purposes.

  • Card and Payment Processor (3rd party) Names & Security Links: We do not process payments directly through this website.

  • Cookie Policy: This website may use essential cookies to ensure basic functionality and analytics cookies to understand how visitors interact with the site. These cookies do not collect personally identifiable information. You can control cookies through your browser settings.

  • AI Policy: We may use AI-assisted tools to support administrative, content, or operational tasks. No personal data is processed by AI systems in a way that would produce legal or similarly significant effects.

  • Third Parties We Share Information With: We may share data with trusted third-party service providers necessary to operate our business, including website hosting (Squarespace), email providers, and scheduling tools. These providers process data only as required to deliver their services and in accordance with applicable data protection laws.

  • Do we transfer your data to any organisations/countries outside the EU/UK? Yes. Some of our service providers (such as Squarespace or email platforms) may process data outside the EU/UK. Where this occurs, appropriate safeguards such as Standard Contractual Clauses (SCCs) are in place to protect your data.

  • IF YES, is this only to ‘adequate’ countries? Yes.

  • Do we use any automated decision making/profiling tools on your data? No.

  • Person responsible for data within our business: Hannah Desmond | hello@hannahdesmondva.com

  • Our data regulator contact details: Information Commissioner’s Office (ICO) | https://ico.org.uk/ (ICO contact email for official records: hello@adhdcoachhannah.com)

  • Are we obliged to collect ID or finance related data for Anti-Money Laundering or other legally required purposes? No.

  • Are we collecting information about people under 16? No.

  • How to raise concerns: If you have concerns about how we handle your personal data, you can raise a complaint directly by email using hello@hannahdesmondva.com. In line with 2026 regulations, we will acknowledge your complaint within 30 days and respond without undue delay. If you are unsatisfied with our response, you may escalate the matter to the ICO.

  • Date this Policy last updated: Tuesday 21st September 2026

WHOSE INFORMATION DO WE COLLECT?

We process information about:

  • "PROSPECTS": contacts working at or connected with potential CLIENTS; potential CLIENTS.

  • "CLIENTS": who have bought goods or services from us, and "CLIENT Contacts" who are individuals employed by or contracted to CLIENTS; children for whom services have been purchased.

  • "SUPPLIERS", "ASSOCIATES": SUPPLIERS or potential SUPPLIERS of goods or services to us.

  • "AFFILIATES/REFERRERS": who have signed up to an AFFILIATE scheme or who have referred PROSPECTS to us.

  • "EMPLOYEES": Our EMPLOYEES if we have any. EMPLOYEES should refer to their contract of employment for data privacy information relating to their own data.

OUR POLICY

We promise respectful treatment of the personal information of everyone we have contact with. We want it to be simple and clear. This Policy explains how we do that—when and why we collect information, how we use it, the situations when other people can see or use it, and how we keep it secure.

We don’t sell, rent, or trade email lists with anyone else.

We’ve split this Policy into sections, depending on who you are:

  • Section A: For everyone (includes information about cookies on our websites).

  • Section B: If you are or work for a business prospect.

  • Section C: If you are a CLIENT or a CLIENT Contact.

  • Section D: If we have information about you purely because we are providing services to a CLIENT.

  • Section E: If you’re a SUPPLIER, ASSOCIATE or AFFILIATE/REFERRER.

For everyone, our intention is to use your information to make things work smoothly for you in your experience of dealing with us.

OUR GENERAL APPROACH TO PERSONAL DATA

We’re committed to protecting your privacy and honouring your legal rights to control how we use your personal data. We only collect and use personal data when we need to:

  • Because you have asked us to do something (for example, send you newsletters);

  • So that we can reply to queries or complaints;

  • To develop and manage our business relationships;

  • To help grow our business and fulfil our contracts;

  • To provide services to CLIENTS;

  • To calculate payments to ASSOCIATES or AFFILIATES/REFERRERS;

  • To meet our legal obligations.

We try to make sure the information we hold is accurate, up to date, and no more than we need to have.

CATEGORIES OF DATA

The types of information that we will be processing depend on the nature of our relationship with you. We may process information about you that you have yourself provided to us or published generally on the internet through social media or on other websites.

In all cases, we will have what identifying and communication information is relevant and that we can sensibly obtain: name, email address, employer or business name, job title or position, contact address, and social media addresses.

  • If you are or work for a prospect: We aim to obtain and process information relevant to building a business relationship and doing business together.

  • If you are or work for a customer or SUPPLIER: We keep records of our interactions, work done or commissioned, progress, and financial and accounting records.

  • If we are processing information purely because we are providing services to others: Please see Section D below. Your rights may be subject to applicable exemptions.

DOWNLOADS, NEWSLETTERS AND SERVICES

We monitor who opens what in our newsletter lists and pre-set sequences to see if content is popular or if it is not read. There may be sub-routines that trigger if you click on links or articles to offer you more information. You can unsubscribe from these sequences at any time.

Existing CLIENTS may receive emails about specific offers relating to things already purchased. We use automation sequences to send requested information, products, or onboarding tips.

We use anonymised data from time to time to target advertising campaigns based on profiling. Sales and marketing people may contact PROSPECTS who have requested a call or where we are actively trying to let you know about something you may benefit from. We prefer building long-term relationships rather than cold calling.

SOCIAL MEDIA

If you interact with us on social media ("like" posts, "follow", or message us), those platforms hold your information in accordance with their own data privacy policies. We keep a record of your direct interactions, which may be seen by authorized staff and ASSOCIATES under strict confidentiality rules.

NO SALE OR EXCHANGE OF YOUR DATA

We do not sell or exchange your personal data with third-party organizations looking to sell you something.

DATA LOCATION AND PLATFORMS

We use mainstream packages for everything from CLIENT records to email and accounting. Some data may be held in the EEA, USA, or elsewhere via mainstream SUPPLIERS with appropriate security standards.

WE MAY SHARE SOME OF YOUR DATA WITH THESE PEOPLE

We have an outsourced support team (Virtual Assistants, Web Designers, IT support, Sales and Marketing, Accounting) who have limited access to your data only when required for their specific service. All team members are bound by strict confidentiality clauses. If you want to know who is on our team, please email and ask us.

HOW LONG DO WE KEEP YOUR DATA FOR?

Your information is kept for the length of time set out in our retention schedule. Newsletter subscribers remain on lists until they unsubscribe.

WANT TO SEE WHAT WE HOLD ON YOU? (SUBJECT ACCESS REQUESTS)

You have the legal right to know what information we hold about you and to receive a copy of it. To make a Subject Access Request (SAR):

  • Email us at hello@hannahdesmondva.com with your name and email address(es). We may require you to confirm your identity before proceeding.

  • In line with UK data protection laws, we will carry out a reasonable and proportionate search of our systems and provide your information free of charge within one month.

  • If your request is broad or requires clarification across extensive data holdings, we may use the official "stop-the-clock" mechanism to pause the response deadline while we briefly ask you for clarification on what specific data you are looking for.

  • Provided we can legitimately disclose the information to you (and it is not restricted by legal exemptions), we will send you what we have.

WHAT ARE YOUR RIGHTS

You have the right to know what information we are collecting on you and to amend it if inaccurate. You also have a "right to be forgotten," though this is subject to legal limits (for instance, if you were a CLIENT, we must retain certain records to comply with legal, accounting, taxation, and insurer requirements). Most information we hold is based on our need to run our business and provide our products/services, rather than individual consent.

OUR LEGAL BASIS FOR PROCESSING YOUR DATA

  • Consent: Signing onto our newsletter list is by consent (which you can withdraw at any time to stop processing).

  • Contract / Legitimate Interest: Most other information is held because we need it to run our business, perform our contracts, or pursue legitimate business interests.

  • Legal Obligation: Relates principally to business, accounting, and tax records.

PROSPECTS, CLIENTS, SUPPLIERS, AND THIRD-PARTY DATA

  • PROSPECTS: We process your name, contact details, source information, and background details to reply to your inquiries and manage potential business relationships. Enquiries are kept for our retention period.

  • CLIENTS: At the point of sale, we collect your email address, phone number, and postal address to provide contracted goods/services, invoice you, and maintain business records.

  • SUPPLIERS, ASSOCIATES AND AFFILIATES: We keep contracts, bank details for payments, invoices, records of work undertaken, and any feedback or complaints to manage our supply chain and business relationships.

  • THIRD-PARTY DATA: If you provide us with personal data relating to your own employees, workers, or clients while we provide services to you, we hold all such information under strict confidentiality obligations.

COMPLAINTS

If you have a complaint about the way we are handling your information or how we responded to a request, you can take it up by emailing us at hello@adhdcoachhannah.com. Under 2026 regulations, we will formally acknowledge your complaint within 30 days and work with you to resolve it without undue delay. If we cannot resolve it to your satisfaction, you can escalate the matter to the Information Commissioner’s Office (ICO) at ico.org.uk.