At Oceanus Leadership Development ("we," "our," or "us"), we are committed to protecting the privacy and security of your personal information. This Privacy Policy outlines how we collect, use, store, and protect information collected from visitors to our website (the "Site") and from clients who engage with us for coaching services, including in relation to the use of artificial intelligence (AI) tools and technologies.
By using our Site, submitting your personal information, or engaging our services, you agree to the terms outlined in this Privacy Policy.
1. Information We Collect
We may collect the following types of personal information when you use our Site or engage our services:
- Personal Identifiers: This includes your name, email address, and phone number
- Communication Data: Any messages, comments, or inquiries you submit through our contact form or other channels on our Site
- Usage Information: Data on how you interact with our Site, such as your IP address, browser type, and other technical information, collected via cookies and similar technologies
- Coaching-Related Information: When you become a client, we may collect and process information you share during coaching sessions, assessments, feedback forms, and related materials necessary to provide our services
2. How We Use Your Information
The personal information we collect from you is used to:
- Respond to Enquiries: We use your contact information to respond to any inquiries you make through our Site
- Provide Services: If you express interest in our executive coaching or team development services, we may use your information to discuss our offerings, provide quotes, or engage with you as a client
- Deliver Coaching Services: Process and use information necessary to provide effective 1:1 coaching, group coaching, leadership development, and related services
- Improve User Experience: We may analyse Site usage data to improve our Site functionality and your experience with us
- Communicate Updates: With your consent, we may send you updates, newsletters, or marketing communications about our services. You can opt out of these communications at any time
- AI-Assisted Activities: We may use AI tools for administrative support, content development, and session preparation as detailed in our AI Policy. Any client information used with AI tools is anonymized and stripped of personally identifiable information
3. Use of Artificial Intelligence (AI)
3.1 Our Use of AI
We may use AI tools to support the delivery and administration of our services in limited ways, including:
- Administrative tasks (scheduling, document preparation)
- Content creation (coaching frameworks, resources, materials)
- Research and preparation for coaching sessions
Important protections when we use AI:
- We anonymize or pseudonymize all client information before using AI tools
- We do not use AI notetakers or recording tools in coaching sessions
- We do not input identifiable client data into AI systems
- We use only AI tools from providers with appropriate data protection measures
- All AI-generated content is reviewed and edited by qualified professionals
3.2 Client Use of AI
Some clients may wish to use AI-powered tools (such as notetakers or transcription services) during coaching sessions. If you wish to use such tools:
- You must obtain explicit consent from your coach before each session
- You are responsible for ensuring compliance with data protection law and your organization's policies
- You must ensure the security and confidentiality of any recordings or transcripts
- We reserve the right to decline consent for AI recording tools
For full details, please see our separate AI Policy.
3.3 Data Protection and AI
When AI is used in connection with our services:
- Processing complies with GDPR, UK GDPR, and the Data Protection Act 2018
- Third-party AI providers are required to have appropriate data processing agreements and security measures in place
- We ensure AI providers do not use client data to train their models (where this can be controlled)
- You have the right to object to AI-assisted processing of your personal data
4. Legal Basis for Processing Your Information
Our processing of your personal information is based on:
- Legitimate Interests: We use your data to respond to your requests, provide our services, and improve our Site
- Consent: Where required by law, we rely on your consent to collect and use certain personal information. You can withdraw this consent at any time by contacting us as described below
- Contractual Necessity: Processing necessary to fulfill our coaching agreement with you
- Legal Obligations: Processing required to comply with legal and regulatory requirements
5. Data Sharing and Disclosure
We do not sell, rent, or trade your personal information to third parties. We may share your information in the following circumstances:
- Service Providers: We may engage third-party service providers to assist with Site maintenance, email communications, data storage, and AI-powered tools. These providers have access to your personal information only to perform services on our behalf and are required to maintain its confidentiality and comply with data protection law
- AI Technology Providers: Where we use AI tools, we ensure providers have appropriate data processing agreements and security measures in place. Client data is anonymized before being processed through AI systems
- Legal Compliance: We may disclose your information if required by law or in response to valid legal requests
- Business Transfers: In the event of a business merger, acquisition, or transfer of assets, your information may be transferred as part of that transaction, subject to the same protections outlined in this Privacy Policy
6. Data Security
We implement industry-standard measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include:
- Secure data storage and transmission protocols
- Access controls and authentication measures
- Regular security reviews and updates
- Contractual protections with third-party service providers
- Anonymization of data used with AI systems
Despite our best efforts, no method of transmission or storage is completely secure. Please contact us immediately if you suspect any unauthorized use of your personal information.
7. Data Retention
We will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with our legal obligations, and enforce our agreements. Specifically:
- Enquiry data: Retained for up to 2 years after last contact
- Client data: Retained for the duration of the coaching engagement plus 7 years for professional indemnity purposes, unless you request earlier deletion
- AI-processed data: Anonymized data used with AI tools is retained only as long as necessary for the specific purpose
If you no longer wish us to retain your information, please contact us as provided below. We will honor your request subject to any legal obligations to retain certain records.
8. Your Rights
Depending on your location, you may have the following rights regarding your personal information:
- Access: Request access to the personal information we hold about you, including information about how AI has been used in connection with your data
- Correction: Request that we correct any inaccurate or incomplete personal information
- Deletion: Request deletion of your personal information, including any data processed through AI tools, subject to certain exceptions
- Restriction: Request that we restrict processing of your personal information under certain circumstances
- Objection: Object to processing of your personal information based on legitimate interests, including objecting to AI-assisted processing
- Data Portability: Request a copy of your personal information in a structured, machine-readable format
- Withdraw Consent: Where processing is based on consent, withdraw that consent at any time
To exercise any of these rights, please contact us as described below. We will respond within the timeframe required by applicable law (typically within one month).
9. International Data Transfers
We primarily store and process data within the United Kingdom and European Economic Area (EEA). Where we use third-party service providers (including AI tools) that may process data outside the UK/EEA, we ensure:
- Appropriate safeguards are in place (such as Standard Contractual Clauses)
- The provider complies with GDPR requirements
- Your data rights remain protected
10. Children's Privacy
Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we discover that a child has provided us with personal information, we will promptly delete it.
11. Cookies and Tracking Technologies
Our website uses cookies and similar technologies to improve functionality and user experience. You can control cookie settings through your browser preferences. For more information, please see our Cookie Policy.
12. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, operational needs, or the use of new technologies (including AI). We encourage you to review this page regularly to stay informed about how we protect your personal information.
Material changes will be notified to active clients via email or through prominent notice on our website.
13. Contact Us and Complaints
If you have questions, concerns, or requests related to this Privacy Policy or our handling of your personal information, please contact us at:
Oceanus Leadership Development
Email: rachel@oceanus-leadership.co.uk
Phone: +44 (0) 7879 411418
If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):
Information Commissioner's Office
Website: www.ico.org.uk
Helpline: 0303 123 1113
14. Related Policies
This Privacy Policy should be read in conjunction with our:
- AI Policy (details about artificial intelligence use)
- Client Agreement and Terms & Conditions
- Cookie Policy
This Privacy Policy is designed to give you confidence in how we handle your personal information. We are dedicated to maintaining your privacy and safeguarding your trust.
Last updated: 23 October 2025