Privacy Policy for Navigating Neurodivergence Ltd

Last updated: 10/06/2026

This privacy notice tells you what to expect us to do with your personal information:

- What information we collect, use, and why

- Lawful bases and data protection rights

- Where we get personal information from

- How long we keep information

- Who we share information with

- International Data Transfers

- How to complain

- Contact details

What information we collect, use, and why:

From clients and people who use our services

We collect and use the following mandatory information, in order that we can deliver services accordingly:

- Contact Names, phone numbers and email addresses (to enable us to schedule coaching sessions, send any relevant resources and communicate with clients between sessions).

- Addresses (only collected from coaching clients for safeguarding purposes, and from clients who buy printed resources, as shipping details)

- Website user information (this is collected by Funnel Sketchers, our third-party client management software, and includes user journeys and cookie tracking, which enables us to ensure clients are able to access any online services and digital downloads. As our website is hosted by Funnel Sketchers, they are in control of any tracking of website cookies; for details of their Funnel Sketchers cookie policy, click here.).

- Payment details where relevant (for any goods paid for by card).

- Call recordings, on occasion (in workshops and webinars that will be made available for resale or for viewing afterwards (all client based content and personal information is edited out before resale) and coaching sessions are available to be recorded at the client’s request).

- If any person under the age of 18 accesses our services, we will also collect the contact names, phone numbers and email addresses of their parents, guardian, teacher or social worker (or another responsible adult if needed) for safeguarding purposes.

We collect and use the following optional information as a recommendation in order that our services can be provided to the best of our abilities:

- Health information (including neurodivergent conditions and occasionally any dietary or other health conditions, in order that we can provide bespoke coaching to suit clients’ needs).

- For coaching clients we request the name and phone number of a safeguarding contact as part of our coaching contract, which is only to be used in case of a genuine safeguarding concern. Provision of this is optional at the discretion of the client although it is recommended.

From people who sign up to our mailing list, via request (by email) or by ticking the permission box on our website

We collect or use the following optional information for sending service updates and for occasional marketing emails:

- Names and email addresses

- Marketing preferences

- Purchase or viewing history

- IP addresses

- Website and app user journey information

- Records of consent, where appropriate

We also collect or use the following special category information for service updates or marketing purposes. This information is subject to additional protection due to its sensitive nature:

- Health information (including neurodivergent conditions)

From coaching clients working with Emma Sails (company director)

We collect or use the following information; to comply with professional requirements (these are required to be stored as a part of our director, Emma Sails’ professional coaching accreditation with the ICF):

- Name

- Email Address

- Dates of commencement and end dates of coaching Number of coaching sessions

From people who send us queries, complaints or claims:

We collect or use the following personal information for dealing with queries, complaints or claims:

- Name, email address and phone number if provided

- Correspondence (usually via email or through our website)

We also collect the following special category information for dealing with queries, complaints or claims. This information is subject to additional protection due to its sensitive nature:

- Health information (including neurodivergent conditions)

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.

Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification. Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure. Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing. Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing. 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. Read more about the right to data portability. Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the bottom of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide services and goods are:

- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.

Our legitimate interests are:

- Collecting your contact details enables us to set up coaching calls and to allow you access to other digital services.

- We also collect health information about your neurodivergent conditions or suspected neurodivergence to ensure that any communities that you access are suited to your needs. (under the explicit consent GDPR clause (Article 9(2)(a)))

Further Recognised Legitimate interests - collecting your contact details enables us to protect the physical, mental or emotional well-being of people who need extra support, or to protect them from harm or neglect (the ‘safeguarding condition’ - Article 9(2)(g) + Schedule 1 DPA 2018, safeguarding of children and individuals at risk). Given that the majority of our clients and people who access our services are neurodivergent, and therefore vulnerable people, we have a professional duty to collect enough information to be able to safeguard them as best we can through the course of the provision of our services. Collecting names, email addresses, phone numbers and addresses enables us to do this more effectively. All of your data protection rights may apply, except the right to object and the right to portability.

 Our lawful bases for collecting or using personal information for service updates or marketing purposes and for dealing with queries, complaints or claims are:

- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information for legal/professional requirements are:

- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

- Our company director, Emma Sails, has an obligation to keep client data as a part of her International Coaching Federation (ICF) credential, occasionally, the ICF may ask to contact clients, but they will never ask about the content of any work done together, only for verification that you have indeed worked with Emma in a coaching capacity.

For more information on our use of legitimate interests on a lawful basis you can contact us using the contact details at the bottom of this privacy notice.

 Where we get personal information from

- Directly from you, via social media, email, telephone or via our website.

- Third parties: From time to time we are passed contact information (names, email addresses and/or phone numbers) as unpaid referrals from private third parties such as business associates, and from the parents, friends and employers of potential clients. As far as we can possibly be aware, this information is always passed to us with the permission of the potential client themselves. Any information obtained by this method is only ever used to establish initial contact and would not be added into my CRM system without further consent.

- No contact information is ever purchased or obtained from publicly available sources.

- We do not use automated decision‑making or profiling.

How long we keep information and how it is stored

- 1:1 coaching and group coaching contracts, containing address details and safeguarding information, are retained for 2 years after the end of our work together (or earlier on request).

- Data stored for professional purposes will be kept indefinitely, or until Emma Sails is no longer registered with the ICF (as per their requirements).

- Notes from any client sessions are handwritten and kept in our offices, and identifiable only by first name. Paper notes are destroyed 2 years after our coaching ends, or earlier on request.

- Card payment details for members of the Navigating Neurodivergence subscription are removed from our system as soon as the subscription ends or if any card details change.

- Contact details of clients, those held for marketing purposes and for any enquiries, complaints or for any other purpose are stored on our CRM system for 3 years after our last interaction, with the last interaction being:

- The date of initial contact (if no further interaction is made)

- The last date which a contact opened an email of ours without clicking the ‘unsubscribe’ option.

Contact details for anyone who unsubscribes from our mailings are removed from any contact lists and added to a “suppression” list to ensure that we do not contact you and then removed after 3 years.

We take appropriate technical and organisational measures to keep your personal information secure, including access controls, encryption where appropriate, and secure storage systems.

 For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details at the bottom of this privacy notice.

 Who we share information with

- Data processors (third parties who assist us in running our business behind the scenes)

- Funnel Sketchers: provides our client management software and hosts our website. The data of any client who contacts us via email or through our website is automatically stored on their system, although they are not actively involved in the management of our business.

- Stripe: store and manage any subscriptions and card payments made to the Company, on their secure systems. Note: Stripe are a US based company,

- The ICF (International Coaching Federation) on their occasional request to confirm coaching activities undertaken by Emma Sails, our company director.

- If there are any safeguarding concerns during coaching, we will share those concerns (without full details, as a brief “I was just speaking to X and they have nominated you as their wellbeing contact; please could you just check in on them for me?”) with your wellbeing contact, in accordance with your signed client commitment and agreement.

 International Data Transfers

We use Stripe to process card payments. This means that if you pay by card for any of our services, some of your personal data may be transferred outside the UK, including to the United States. Stripe, LLC is self‑certified under the UK Extension to the EU–US Data Privacy Framework, which provides an adequate level of protection for international transfers. Where the Data Privacy Framework no longer applies, Stripe relies on the UK International Data Transfer Addendum (IDTA) or the UK Addendum to the EU Standard Contractual Clauses as appropriate safeguards.

You can find more information in Stripe’s Data Transfers Addendum or contact us at the details below if you would like further details about these safeguards.

 How to complain

If you have any concerns about our use of your personal information, you can make a data protection complaint to us by email to [email protected], or directly to the ICO at their website here.

Our full terms and conditions are available to view here.

 Contact Us

If you have any questions about this privacy policy, You can contact us:

By email: [email protected]

By visiting this page on our website: https://navigatingneurodivergence.co.uk/ By phone: 07809238566