Think on Purpose

Our contact details

Think on Purpose is a trading name of Conoma Limited. We provide coaching, leadership development, training and adaptability assessments. Conoma Limited is the data controller for the personal information described in this policy. This means we decide how it is used and we are responsible for looking after it. In this policy, “we”, “us” and “our” mean Conoma Limited, trading as Think on Purpose.

The type of personal information we collect

We currently collect and process the following information:

Potential, existing and previous clients and coachees:

• name, email, address, phone number, job title and organisation,
• the type of work expected and delivered,
• coaching session notes and notes of meetings, and, only with your agreement, session recordings or transcripts,
• assessment results (for example AQai reports) that you choose to share with us.

• People taking part in our workshops, training and online courses: name, contact details, attendance, course progress and feedback
• Associates and collaborators who deliver work with us
• Client and supplier payment details, and supplier bank details
• Newsletter and marketing contacts
• Enquiries made through our website, email or booking system
• Information about how people use our website, collected through cookies (see “Cookies” below)

We do not ask for sensitive (“special category”) information such as health details. If you choose to share something of this kind during coaching, we will record only what is needed to support you, and only with your explicit consent.

How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you for one of the following reasons:

• Working with you as a client, including quoting for, preparing and delivering coaching, training and workshops
• Online courses and digital products bought through our website
• Booking calls and sessions
• Marketing and newsletters (you can unsubscribe at any time)
• Client feedback, surveys and evaluation
• Case studies and testimonials, only ever with your permission
• Paying suppliers and associates
• Our website and contact form

We also receive personal information indirectly, from the following sources in the following scenarios:

• Your employer or organisation, when they commission coaching or training for you
• Assessment platforms such as AQai, when you choose to share your results with us
• People who introduce or refer you to us
• Government bodies such as HMRC

We use your information to deliver and support the services we provide. We do not sell your information to anyone.

We only share it where we need to: with associates delivering your programme, with the service providers who help us run the business (described below), with professional advisers such as our accountant, and with government bodies or regulators where the law requires it.

If your organisation has commissioned coaching for you, we agree at the start what, if anything, is reported back to them. What you say in coaching stays confidential unless you agree otherwise, or unless there is a serious risk of harm to you or someone else. In line with the EMCC Global Code of Ethics, we may discuss anonymised coaching themes in professional supervision.

When we deliver work on behalf of another organisation, such as an employer, a council or a public body, that organisation may be the data controller for some of your information and its own privacy notice will also apply. We will tell you at the start if this is the case.

Under UK data protection law (the UK GDPR, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations), the lawful bases we rely on are:

Where we rely on your consent, you can withdraw it at any time by contacting admin@thinkonpurpose.co.uk.

Every marketing email includes an unsubscribe link, and you can object to marketing at any time.

If you choose to share special category information with us during coaching (for example about your health), we rely on your explicit consent to record it.

How we store and protect your personal information

Our IT systems are managed and protected by a managed IT and cyber security provider based in the North West of England, who provide our IT support and cyber security protection.

Backups of our computer are kept on a separate external hard drive, which is encrypted and stored locked away when not in use.

All systems and accounts that hold personal information are protected by passwords and two-factor authentication.

We use a small number of trusted platforms to run the business, each with its own security and privacy standards. These include Microsoft 365 and Google Workspace (email and documents), Zoom (online sessions), Calendly (booking), Kajabi (online courses and newsletters) and QuickBooks (accounts).

We also use assessment platforms such as AQai, where individuals voluntarily submit their own details. Anyone using these platforms, including Think on Purpose, is also bound by each platform’s own privacy policy.

We use some AI-assisted tools for administrative tasks, such as tidying up notes or transcripts. We keep identifying details to a minimum and use account settings that stop your information being used to train AI models.

We only record sessions with your agreement, and we will always ask before recording starts.

Some of these providers are based outside the UK, so your information may be processed abroad. Where this happens, it is protected by UK adequacy regulations, or by the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.

If a data breach ever occurred that was likely to put your rights at risk, we would report it to the ICO within 72 hours and let you know without undue delay.

Cookies

Our website uses cookies. Essential cookies make the site, course area and checkout work. We only use analytics or marketing cookies with your agreement, which you can give or withdraw at any time through our cookie settings.

Our online courses are hosted on Kajabi, which sets its own cookies to keep you logged in and process payments. You can change your cookie choices at any time by clearing the cookies in your browser, which will show our cookie banner again, or by contacting us.

How long we keep your information

We review the information we hold every year.

Client and financial records

Six years after our work together ends, as required for tax and legal purposes

Coaching notes and assessments

Two years after our coaching ends

Session recordings

Deleted within 30 days, once notes or transcripts are complete

Course and workshop participants

Two years after your course access ends

Website enquiries with no work

12 months

Associates and collaborators

Six years after our last work together

Marketing contacts

Until you unsubscribe or ask us to remove you

After that, we securely delete or destroy your information, unless we need to keep it longer for legal or compliance reasons.

Your data protection rights

Under data protection law, you have rights including:

• Your right of access – You have the right to ask us for copies of your personal information.
• Your right to rectification – You have the right to ask us to correct personal information you think is inaccurate, or to complete information you think is incomplete.
• Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances, and you can always object to direct marketing.
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
• Your right to withdraw consent – Where we rely on your consent, you can withdraw it at any time.
• Automated decisions – We do not make decisions about you based solely on automated processing, including profiling.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. If your request is complex, or you make several, we may extend this by up to two further months, and we will tell you if we need to.

Please contact us at admin@thinkonpurpose.co.uk or write to Jen Brierley-Masheter, Think on Purpose, ‘The Space’, 35-37 High Street, Congleton, Cheshire, CW12 1AX, if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, please contact us first at admin@thinkonpurpose.co.uk with the subject header DATA PRIVACY REQUEST. We will acknowledge your complaint within 30 days and let you know the outcome without undue delay.

If you are unhappy with our response, you can complain to the Information Commission, the UK’s data protection regulator (formerly the Information Commissioner’s Office, or ICO).