Effective Date: 17 February 2025

Last Updated: 18 July 2025

We take your privacy seriously.

Your transformation journey is deeply personal, and we honor that by protecting your information with the same care we bring to our coaching. This Privacy Policy explains how we collect, use, share, and protect your personal information across our ecosystem of services, ensuring full compliance with UK GDPR and other applicable data protection laws.

Our Mission: Liberating Value — helping people unlock the insight, strength and direction they need to lead with purpose and live with balance.

This policy applies to all services within the Liberating ecosystem:

• liberating.io (main hub and thought leadership)

• liberating.me (personal transformation services) [Planned]

• liberating.work (corporate solutions) [Planned]

• liberating.health (holistic wellness programs) [Planned]

• liberating.community (conscious connection platform) [Future Service]

• liberating.earth (sustainable products and experiences) [Planned]

Note: Services marked as “Planned” or “Future Service” are not yet active. This policy will be updated when these services launch, and users will be notified of any changes.

Who we are

Company: Liberating IO Limited

Address: 22 Bloomfield Avenue, Bath, BA2 3AB

Email: adam@liberating.io

Phone: +44 (0)7540 102075

ICO Registration: ZB866880 (expires 16 February 2026)

Data Controller: Adam Jackson, Certified ICF Coach

Data Protection Officer: Adam Jackson (adam@liberating.io)

Registered Address: 22 Bloomfield Avenue, Bath, BA2 3AB

What personal information we collect and why we collect it

We collect personal information thoughtfully and only when it serves your transformation journey or our legitimate business operations. Here’s what we collect and why:

Personal Information You Provide

Discovery and Assessment Information: When you’re exploring coaching or complete assessments, we collect:

• Name, email address, phone number

• Professional background and current role

• Coaching goals and aspirations you’re seeking to achieve

• Saboteur Assessment responses (Positive Intelligence®) to understand your mental patterns

• Personal and professional challenges you’re facing

• Values and motivations assessment responses to personalize your coaching

Coaching Session Information: To support your ongoing development and ensure continuity in your coaching journey, we collect:

• Session notes and insights (with your consent) focusing on progress and action items

• Action items and commitments you make during sessions

• Progress tracking and outcomes to measure your transformation

• Reflection journals and worksheets you choose to share

• Session recordings and AI-generated transcripts (with explicit prior consent only)

Payment and Billing Information: For processing payments and maintaining accurate business records:

• Billing address and payment method details

• Transaction history and invoice records

• Corporate billing contact information for organizational clients

Communication Records: To maintain professional relationships and provide quality service:

• Email correspondence between us

• Calendar scheduling information for appointment coordination

• Session recordings (with explicit consent only) for your development benefit

• Workshop attendance and participation records

Information Automatically Collected

Website Analytics: To improve our website experience and understand how our content serves visitors:

• IP address and general location for security and analytics

• Browser type and device information for technical optimisation

• Pages visited and time spent to understand content effectiveness

• Referral sources and search terms to improve our outreach

• Cookie and similar tracking technology data as detailed in our Cookie Policy

Platform Usage: To enhance your experience with our digital services:

• Login times and frequency for security monitoring

• Feature usage and engagement patterns to improve our programs

• Community participation metrics (when community platform launches)

• Resource download history to share relevant materials

Information from Third Parties

Professional References: When building our coaching relationship or for corporate programs:

• Referral information from colleagues or previous coaches (with consent)

• Professional background verification (with your explicit consent)

Integrated Service Providers: Through the technology platforms we use to serve you:

• Calendar integration data (Google Calendar, Outlook) for seamless scheduling

• Video conferencing attendance records for session tracking

• Payment processing confirmations for transaction verification

How we use your information - Legal basis and practical purposes

We process your personal information based on the following legal grounds under UK GDPR, and use your information to support your transformation journey and maintain our professional coaching practice:

Legitimate Interests

Our legitimate interests in delivering high-quality coaching and transformation services include:

Primary Service Delivery:

• Designing personalized coaching programs that truly serve your individual goals

• Tracking your progress and measuring outcomes to ensure effective transformation

• Providing accountability and ongoing support throughout your journey

• Delivering Mental Fitness training via Positive Intelligence® methodology

• Facilitating mindfulness and wellness programs that support holistic development

Business Operations and Improvement:

• Analyzing usage patterns to enhance our programs and make them more effective

• Gathering feedback to improve service delivery and develop new offerings

• Developing new services based on client needs and transformation outcomes

• Researching industry trends and best practices to stay current in our field

• Building thought leadership authority to serve the coaching profession

Contractual Necessity

To fulfill our coaching service agreements and provide the services you’ve purchased:

Service Fulfillment:

• Processing payments and managing billing for your coaching programs

• Providing access to purchased programs, resources, and community features

• Delivering the specific coaching services outlined in your agreement

• Coordinating logistics for workshops, sessions, and events

Consent

For activities that require your explicit permission:

Optional Communications and Marketing:

• Sending marketing communications and newsletters (you can unsubscribe anytime)

• Recording coaching sessions when you feel it would benefit your development

• Sharing anonymized success stories and testimonials to inspire others

• Using information for research and thought leadership (always anonymized)

Legal Obligation

To meet our professional and legal requirements:

Compliance and Professional Standards:

• Maintaining business records as required by UK law and professional coaching standards

• Reporting suspicious activities when legally required

• Cooperating with law enforcement when legally compelled

• Meeting ICF Code of Ethics and other professional certification requirements

Who we share your information with - And who we don’t

We don’t sell or rent your information to anyone. Ever.

When We Share Information (With Your Knowledge and Consent)

With Your Explicit Consent:

• Sharing success stories and testimonials (always anonymized unless you specifically request attribution)

• Collaborating with other professionals in your transformation journey when you request it

• Providing references or recommendations when you ask us to support your goals

Service Providers and Business Partners We Trust: To deliver our coaching services effectively, we work with carefully selected technology providers who maintain strong privacy protections:

• Payment processors (Stripe, Wise) for secure transaction processing

• Financial management (Xero) for accounting and business record keeping

• Calendar services (Calendly, Google Calendar) for seamless appointment scheduling

• Email services (ConvertKit) for newsletter communications (only if you subscribe)

• Website hosting (Squarespace) and analytics providers for our online presence

• Video conferencing platforms (Zoom, Google Meet) for virtual coaching sessions

• CRM systems (HubSpot) for professional client relationship management

• Form processing (Typeform) for assessments and inquiries

• Automation services (Zapier) for workflow integration between platforms

• Cloud storage (Google Workspace, Notion) for secure document management

• AI transcription services (Zoom AI) for session recordings (with explicit consent)

Corporate Clients (With Clear Boundaries): For corporate coaching programs, we may share:

• Aggregate program metrics and outcomes (never individual personal details without consent)

• Progress reports to designated organizational contacts (as agreed in advance)

• Program logistics coordination with HR teams (limited to scheduling and participation)

Legal Requirements (Only When Compelled): We’ll only share your information when:

• Required by law or legal process (court orders, subpoenas)

• Necessary to protect against fraud or security threats

• In emergency situations to protect health and safety

What We Never Share

We will never:

• Sell your personal information to third parties for any reason

• Share specific coaching session content without your explicit written consent

• Disclose individual assessment results to employers without your written permission

• Use your information for advertising unrelated services to you

• Share your contact information with other participants without your permission

• Provide your information to marketing companies or data brokers

International data transfers

As a UK-based business, we primarily process data within the UK and European Economic Area to ensure the highest privacy protections. When we use service providers outside these regions (such as certain technology platforms), we ensure:

• Adequate protection through Standard Contractual Clauses approved by UK authorities

• Service providers maintain equivalent data protection standards to UK GDPR

• Regular review of international transfer arrangements and security measures

• Your rights remain fully protected regardless of where processing occurs

• Clear contractual obligations for data protection with all international providers

How long we keep your information - Data retention periods

We keep your information only as long as necessary to support your transformation journey and meet our legal obligations:

Retention Periods

Active Coaching Relationships:

• Personal information: Duration of our working relationship plus 7 years for potential future support

• Session notes and assessments: Duration of relationship plus 3 years for service improvement

• Payment records: 7 years from final transaction (required for accounting and tax purposes)

Completed Programs:

• Contact information: 3 years after program completion in case you want to restart coaching

• Progress and outcome data: 3 years for service improvement purposes, then securely deleted

• Testimonials and success stories: Indefinitely (with your ongoing consent, which you can withdraw)

Community Members (when platform launches):

• Active membership data: Duration of membership plus 1 year for potential re-engagement

• Participation records: 2 years after membership ends for community improvement

• Content contributions: Indefinitely (with attribution as you desire, which you can modify)

Marketing Communications:

• Email marketing lists: Until you unsubscribe plus 1 year for compliance verification

• Website analytics: 26 months (Google Analytics standard retention period)

• Contact form inquiries: 3 years or until conversion to client relationship

Session Recordings and Transcripts:

• Recordings with consent: Automatically deleted after 3 years unless you request extension

• AI transcripts: Same retention period as recordings

• Available for your deletion upon request at any time during retention period

Secure Deletion Process

When retention periods expire, we:

• Securely delete or anonymize personal information using industry-standard methods

• Remove data from backup systems within 90 days of deletion request

• Maintain only anonymized data for research and service improvement purposes

• Provide written confirmation of deletion upon your request

Your rights - You’re in control of your information

Under UK GDPR, you have comprehensive rights regarding your personal information, and we’re committed to making these rights easy to exercise:

Access and Portability Rights

• Right to Access: Request copies of all personal information we hold about you

• Data Portability: Receive your data in a structured, machine-readable format for transfer

• Response Time: We’ll respond within 1 month of your request (may extend to 3 months for complex requests)

Correction and Deletion Rights

• Right to Rectification: Correct any inaccurate or incomplete information we hold

• Right to Erasure: Request deletion of your personal information (subject to legal retention requirements)

• Right to Restrict Processing: Limit how we use your information while disputes are resolved

Communication and Consent Management

• Marketing Opt-out: Unsubscribe from marketing communications at any time using email links

• Consent Withdrawal: Withdraw consent for specific processing activities like session recording

• Objection Rights: Object to processing based on legitimate interests for marketing purposes

How to Exercise Your Rights

Contact Method: Email: privacy@liberating.io

Subject Line: “Data Protection Request - [Type of Request]”

Required Information: Full name, email address used with our services, specific request details

Response Time: Within 1 month (we’ll notify you if we need to extend this for complex requests)

No Fee Required: We don’t charge for most data protection requests unless they’re clearly unfounded or excessive

Security measures - Keeping your information safe

We protect your personal information using comprehensive technical, physical, and administrative safeguards:

Technical Safeguards

Data Encryption and Security:

• All data transmitted using SSL/TLS encryption for secure communication

• Stored data encrypted using industry-standard AES encryption methods

• Regular security audits and vulnerability assessments conducted

• Multi-factor authentication required for all system access

• Role-based permissions limiting data access to essential personnel only

Backup and Recovery:

• Encrypted, geographically distributed backups for data protection

• Regular backup testing and recovery procedure validation

• Business continuity planning for service disruptions

• Secure backup retention and deletion procedures

Physical and Administrative Safeguards

Device and Facility Security:

• Encrypted devices with secure password policies and automatic locking

• Regular software updates and security patches applied promptly

• Secure disposal of hardware and storage media when replaced

• Private, secure office environment for all coaching activities

Personnel and Process Security:

• Regular data protection training for all staff and contractors

• Confidentiality agreements and ethical guidelines for everyone with data access

• Clear incident response and breach notification procedures established

• Regular review of access permissions and security protocols

Incident Response Procedures

In the unlikely event of a security incident, we have procedures to:

• Immediately contain the incident and assess its impact on your information

• Notify relevant authorities within 72 hours when legally required

• Provide direct notification to affected individuals when legally required or advisable

• Conduct full investigation and implement corrective actions to prevent recurrence

• Document lessons learned and improve security measures accordingly

Professional coaching confidentiality - ICF standards and beyond

Professional Standards We Follow

As a certified ICF coach, Adam Jackson adheres to the highest professional standards:

• ICF Code of Ethics and comprehensive confidentiality requirements

• Co-Active Training Institute professional guidelines and best practices

• Positive Intelligence, LLC certification requirements and ethical standards

• UK professional coaching best practices and continuing education requirements

Session Confidentiality Framework

Recording and Transcription Consent:

• Session recordings are only made with your explicit prior written consent for each session or series

• AI-generated transcripts (via Zoom AI) require separate, specific consent beyond recording consent

• All recordings and transcripts are stored securely and subject to the same confidentiality standards as live sessions

• Recordings are automatically deleted after 3 years unless you request extension or earlier deletion

• You can request deletion of recordings at any time without affecting continuation of coaching services

• You may withdraw consent for future recordings at any time while maintaining your coaching relationship

What Remains Absolutely Confidential:

• All content discussed in coaching sessions, whether recorded or not

• Personal assessments and their specific results and interpretations

• Individual goals, challenges, and breakthrough moments you experience

• Any information you specifically mark as confidential or particularly sensitive

• Your participation in coaching programs (unless you choose to share this information)

Very Limited Exceptions to Confidentiality: We would only break confidentiality in these specific circumstances:

• Immediate danger to self or others requiring emergency intervention (legal duty to report)

• Court orders requiring disclosure (with prior notification to you when legally possible)

• You explicitly request information sharing with designated parties in writing

Corporate Coaching Confidentiality Boundaries

For corporate coaching programs, we maintain strict boundaries:

• Individual session content remains completely confidential between coach and participant

• Only aggregate, anonymized progress metrics are shared with organizations (as pre-agreed)

• Clear written agreements specify exactly what information, if any, will be shared with employers

• Explicit written consent required for any individual-specific reporting to organizations

• Participants can request that certain topics remain completely confidential even from aggregate reporting

Cookies and tracking - Website functionality and your choices

Types of Cookies We Use

Essential Cookies (Always Active - Cannot Be Disabled): These cookies are necessary for our website to function properly:

• Session management and user authentication for secure access

• Shopping cart and payment processing functionality

• Security and fraud prevention measures

• Basic website functionality and navigation

Analytics Cookies (Optional - Your Choice): These help us understand how to improve our website:

• Google Analytics for website usage insights and improvement

• Squarespace Analytics for platform-specific performance data

• Visitor behavior analysis for service enhancement

• Conversion tracking for marketing effectiveness measurement

Marketing Cookies (Optional - Your Choice): These help us provide relevant content and measure our outreach:

• Social media integration and content sharing functionality

• Email marketing integration for newsletter subscribers

• Professional network advertising optimization (LinkedIn)

• Retargeting for relevant content and service information

Your Cookie Choices and Control

Cookie Management Options:

• Most browsers allow you to block or delete cookies through settings

• Our website provides a cookie banner for granular preference management

• You can opt-out of major advertising networks through industry tools

• We respect browser “Do Not Track” signals where technically feasible

Impact of Different Cookie Choices:

• Blocking Essential Cookies: May significantly affect website functionality and user experience

• Blocking Analytics Cookies: No impact on your service delivery, but reduces our ability to improve the website

• Blocking Marketing Cookies: You may receive less relevant communications and content recommendations

Third-Party Tracking Services

We use these third-party services for website analytics and improvement:

• Google Analytics: Website performance and user behavior analysis

• Squarespace Analytics: Platform-specific hosting analytics

• HubSpot Tracking: Customer relationship management and communication

• ConvertKit Tracking: Email marketing engagement for newsletter subscribers

• LinkedIn Insight Tag: Professional network engagement (when applicable)

Full details about cookie usage, retention periods, and management options are available in our separate Cookie Policy.

Children’s privacy protection

Age Restrictions and Protections:

• Our coaching services are designed for adults (18+ years) and business professionals

• We do not knowingly collect personal information from children under 16 years of age

• Parent/guardian consent is required for any coaching services provided to minors (16-18 years)

If We Discover Information from Minors:

• Immediate secure deletion of any collected information

• Notification to parent/guardian when contact information is available

• Implementation of additional safeguards to prevent future collection from minors

Updates to this policy - How we communicate changes

Change Notification Process

How We’ll Notify You of Updates:

• Email notification to all active clients and community members

• Prominent website notice displayed for 30 days following any changes

• Updated “Last Modified” date prominently displayed at the top of this policy

• Clear summary of what has changed in our notification communications

Types of Changes Requiring Special Notice:

• New types of personal data collection or sharing arrangements

• Changes in the legal basis for processing your information

• Modifications to your rights or our security practices

• Updates to data retention periods or international transfer arrangements

• Changes to third-party service providers handling your information

Your Continued Participation: Continued use of our services after policy updates constitutes acceptance of changes, unless you object in writing within 30 days of notification. If you disagree with updates, please contact us to discuss your options, which may include data deletion or service modification.

Contact information - Getting help and support

General Privacy Questions

Primary Contact:

Adam Jackson, Liberating IO Limited

22 Bloomfield Avenue, Bath, BA2 3AB

Email: adam@liberating.io

Phone: +44 (0)7540 102075

Data Protection Specific Inquiries

Data Protection Officer: Adam Jackson

Email: privacy@liberating.io

Response Time: Within 48 hours for acknowledgment, full response within 1 month Postal Address: 22 Bloomfield Avenue, Bath, BA2 3AB

Regulatory Complaints and External Support

If you’re unsatisfied with our response to your privacy concerns:

UK Information Commissioner’s Office (ICO)

Website: ico.org.uk

Phone: 0303 123 1113

Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

When to Contact the ICO:

• We haven’t responded to your data protection request within required timeframes

• You believe we’re not complying with data protection law

• You’re unsatisfied with how we’ve handled your complaint

• You want independent advice about your data protection rights

Domain-specific privacy considerations

Liberating.community Platform (Future Service)

When our community platform launches, additional data collection will include:

• Community profile information and member preferences for connection

• Peer interaction and networking data to facilitate meaningful relationships

• Group participation and contribution metrics for community improvement

• Member-generated content and discussion participation

Community-Specific Privacy Rights:

• Right to modify your community profile and visibility settings at any time

• Option to participate anonymously in certain community activities

• Granular control over visibility of your participation and contributions to other members

• Ability to delete your community account while retaining access to other Liberating services

Liberating.health Wellness Programs (Planned)

Health Information Handling:

• Lifestyle assessment information will be treated as sensitive personal data with enhanced protections

• Additional security measures implemented for any health-related content or recommendations

• Compliance with healthcare information privacy standards where applicable

• Clear, separate consent processes for any health data sharing with third parties

Important Medical Disclaimer: Our wellness programs provide education, guidance, and training to support your holistic wellbeing journey. However, we are not medical professionals and do not provide medical advice, diagnosis, or treatment. Our services are designed to complement, not replace, professional healthcare. You should always consult with qualified healthcare practitioners for medical concerns, before making significant lifestyle changes, or if you have any health conditions that may be affected by wellness practices.

Mindfulness and Meditation Data:

• Practice tracking and progress metrics to support your wellness journey

• Meditation session attendance and engagement for program improvement

• Wellness goal setting and achievement tracking for personal development

• Optional integration with personal health applications (with explicit consent)

Liberating.work Corporate Services (Planned)

Corporate Data Handling Framework:

• Clear data processing agreements with corporate clients defining roles and responsibilities

• Defined boundaries between individual participant data and organizational reporting

• Separate consent processes for individual coaching data versus organizational program data

• Enhanced security measures for business-sensitive information and intellectual property

Employee Privacy Protection:

• Individual coaching sessions remain confidential even in corporate programs

• Aggregate reporting only, with no individual identification without explicit consent

• Clear policies for handling workplace conflicts or performance issues that arise in coaching

Liberating.earth Product Platform (Planned)

E-commerce Data Collection:

• Purchase history and product preferences for improved recommendations

• Shipping and delivery information for order fulfillment

• Product reviews and rating data for community benefit

• Sustainable living assessment information for personalized product curation

Product-Related Privacy:

• Integration with sustainable living values and lifestyle choices

• Optional sharing of product experiences with community members

• Clear consent for any product usage data collection

• Transparent supply chain and ethical sourcing information

Conclusion

This Privacy Policy reflects our deep commitment to transparency, security, and genuine respect for your personal information. As we expand our ecosystem of transformation services, we will continue to uphold the highest standards of data protection while enabling the powerful personal and professional growth that our clients experience.

Our approach to privacy, like our approach to transformation, is grounded in the principle that “what we achieve inwardly changes outward reality.” By protecting your inner journey—your goals, challenges, and breakthrough moments—we create the safe space necessary for authentic transformation.

We believe that trust is the foundation of any transformational relationship. This comprehensive policy ensures that trust is well-placed, backed by robust legal protections, professional ethical standards, and genuine care for your privacy and confidentiality.

For any questions about this policy or how we handle your information, please don’t hesitate to reach out. We’re here to support your transformation journey with complete transparency, unwavering confidentiality, and the highest professional standards.

Document Version: 2.0

Next Review Date: 18 January 2026

Legal Framework: UK GDPR Compliant

Professional Standards: ICF Code of Ethics Aligned