Privacy Policy

Last Updated: 04 March 2025

At Sexton Pendleton Limited (trading as Emily Sexton Coaching) ("we", "us", "our"), we are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you engage our services or visit our website emilysextoncoaching.org (hosted by Squarespace) in compliance with the General Data Protection Regulation (GDPR) and UK data protection laws. This Privacy Policy does not apply to the practices of third parties that we do not own or control.

By using our website and engaging our services, you agree to the terms outlined in this policy. If you do not agree with this policy, please do not use our website.

1. Who We Are

We are Sexton Pendleton Limited, a Leadership Development & Coaching provider, trading as Emily Sexton Coaching, registered at 71-75 Shelton St, London WC2H 9JQ. For privacy-related inquiries, you can contact us via email at emilysextoncoaching@gmail.com.

2. Information We Collect

We collect personal data from you when you interact with our website and use our services, including:

a. Personal Information When you fill out forms on our website (e.g., contact forms, subscription forms, or make a purchase), we may collect:

  • Your name

  • Email address

  • Phone number (if provided)

  • Billing and shipping address (if provided for orders)

  • Payment details (processed by third-party providers)

b. Special Category Data In the course of providing coaching services, we may collect special category data, including psychometric data (e.g., personality assessments or other feedback data related to your professional behaviour and characteristics. This data is processed in accordance with Article 9 of the UK GDPR.

3. How We Use Your Data

We use your personal data for the following purposes:

  • To provide services: We use your personal data to process orders, communicate with you, and provide services you’ve requested.

  • To improve our website: We use usage and analytics data to monitor website performance and improve the user experience.

  • Marketing communications: If you have opted in, we may send you newsletters, promotions, or other marketing communications. You can opt out at any time.

  • To comply with legal obligations: We may use your data to comply with legal requirements, such as tax and accounting obligations.

  • To process special category data: Specifically for leadership development and coaching services, we process psychometric data and feedback data to deliver personalised coaching, development, and leadership assessments.

4. Legal Basis for Data Processing

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds:

  • Consent: When you provide personal information via forms or sign up for communications (e.g., newsletter).

  • Contractual necessity: If you enter into a contract with us, such as making a purchase, we need to process your data to fulfil the contract.

  • Legitimate interests: We may process your data for legitimate business interests, such as improving our website or marketing communications, provided this does not override your rights.

  • Legal obligations: We may need to process personal data to comply with legal requirements, such as tax reporting, responding to legal processes, addressing security issues, or financial record-keeping.

  • Special Category Data (Article 9): For psychometric data and feedback data, processing is based on explicit consent as required by Article 9 of the UK GDPR.

5. Sharing Your Data

We do not sell or share your personal data with third parties for their marketing purposes. However, we may share your data with the following categories of third parties for the purposes outlined in this policy:

  • Payment processors: Third-party payment services (e.g., Stripe, PayPal) to process transactions. These providers may collect and process your payment information.

  • Email marketing services: To send marketing communications. These services may collect your email address for the purpose of sending emails.

  • Website analytics providers: We use tools such as Google Analytics and Squarespace Analytics to help us understand website traffic and user behavior.

  • Other service providers: For limited reasons/in limited circumstances, we may share data with other service providers who help us operate and manage our business (e.g., IT services, hosting services).

Data Processors for Special Category Data:

We work with Edgcumbe Consulting Group as Data Processors to assist in processing psychometric and 360 feedback data as part of our coaching services. They process this data on our behalf and in line with our instructions. For further details, please refer to their Data Processing Agreement: Edgcumbe Data Processing Agreement.

We work with 3 Minute Mile as Data Processors to assist in processing psychometric (Hogan Assessments) as part of our leadership development and/or coaching services. They process this data on our behalf and in line with our instructions. For further details, please refer to their Policy.

All third parties with whom we share your data are required to respect your privacy and comply with relevant data protection laws.

6. Data Retention

We will retain your personal data only as long as necessary to fulfill the purposes for which it was collected, including for legal and regulatory purposes. For example, we may retain transaction data for financial record-keeping and tax reporting. Special category data (psychometric and feedback data) will be retained only for the duration of your coaching programme and as long as required to meet compliance and contractual obligations.

7. Your Rights Under GDPR

Under GDPR, you have the following rights regarding your personal data:

  • Right to Access: You have the right to request access to the personal data we hold about you.

  • Right to Rectification: You can request that we correct any inaccuracies in your personal data.

  • Right to Erasure: You can request that we delete your personal data, subject to certain legal exceptions.

  • Right to Object: You can object to certain types of data processing, such as marketing communications.

  • Right to Data Portability: You can request that we transfer your personal data to another provider in a structured, machine-readable format.

  • Right to Withdraw Consent: If we process your data based on consent, you can withdraw your consent at any time.

To exercise any of these rights, please contact us at emilysextoncoaching@gmail.com.

8. Squarespace and Data Collection

Our website is hosted by Squarespace, a third-party website builder and hosting platform. Squarespace collects data through its hosting services, including:

  • Device Information: Information such as browser type, device type, and operating system.

  • Usage Data: Information about how visitors interact with our website, including the pages viewed and time spent on each page.

  • IP Address: Squarespace collects IP addresses to monitor traffic and security.

  • Analytics: Squarespace uses data (including cookies and similar technologies) to help us analyze website traffic, user behavior, and improve the user experience.

For more detailed information on Squarespace's data collection practices, please refer to their Privacy Policy.

9. Updates to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page, and the date of the most recent update will be indicated at the top of this page.

10. Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact Sexton Pendleton Limited at: emilysextoncoaching@gmail.com.

By using our services and/or website, you acknowledge and agree to the terms outlined in this Privacy Policy.