PRIVACY POLICY

 

  1.  Who we are

This privacy policy is issued by Stella Communications Ltd trading as “LEAD with Abi” (“we”, “us” or “our”), a company registered in England and Wales with company number 13210120 with its registered office at 3 Gilletts Lane, East Malling, West Malling, Kent, England, ME19 6AS. We are a controller of your personal data and are responsible for ensuring that it is properly protected. We are registered with the Information Commissions Office in the UK with reference ZB912257.

Please see the 'How to contact us' section at the end of this privacy policy if you have any questions about this privacy policy or the data we hold about you.

  1.  This privacy policy

Please read this privacy policy carefully as it contains important information about who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

This privacy policy explains how we collect and process information about you if you are:

  1. a website visitor that is using our website at leadwithabi.com;
  2. a recipient of our coaching services and/or user of our online coaching portal; or
  3. a business contact, including a member of personnel at a business that we have referral arrangements in place with.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK data protection laws. If you are located in the European Economic Area (EEA), we are also subject to the EU General Data Protection Regulation (EU GDPR) and other local laws in relation to services we offer to individuals in the EEA.

  1.  Our collection and use of your personal data

Personal data means any information about an individual from which they can be identified, whether directly or indirectly. It does not include anonymised data, which is data that can no longer be associated with you.

How your personal data is collected

We collect personal data about you in different ways, including:

  • Direct interactions. You may give us your personal data when you use our website, register with us as a coaching participant or coaching portal user, sign up to our mailing list, send us feedback, or purchase services from us.
  • Automated technologies or interactions. As you interact with our website or online coaching portal, we will automatically collect Technical Data (defined below) about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
  • Publicly available sources. We will receive Identity and Contact Data about you from various publicly available sources including Companies House, your social media profiles, your own website and third party sites such as Google and Amazon. We predominantly use information from these publicly available sources for business-to-business marketing purposes.
  • Third parties. We may sometimes receive Technical Data and Identity and Contact Data from third parties, including business partners, social media companies and analytics providers. This is predominantly for referral purposes, as well as online analytics.

Personal data we collect about you

The personal data we collect about you depends on how and why you engage with us.

If you are a website visitor, we may collect the following information about you:

  • Identity Data - full name, marital status, title, date of birth and gender.
  • Contact Data - address, email address and telephone number(s).
  • Technical Data - internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data - data about how you use our website, including survey responses.
  • Marketing and Communications Data - your preferences in receiving marketing from us and your communication preferences.

If you are a recipient of our coaching services and/or user of our online coaching portal, we may collect the following information about you:

  • Identity Data - full name, marital status, title, date of birth and gender.
  • Contact Data - address, email address and telephone number(s).
  • Profile Data - your username and password for the online coaching portal, orders made by you and coaching sessions completed by you, your interests and preferences.
  • Technical Data - internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data - data about how you use our website, including survey responses.
  • Marketing and Communications Data - your preferences in receiving marketing from us and your communication preferences.
  • Financial Data - bank account and payment card details.
  • Transaction Data - details about payments to and from you and other details of services you have purchased from us
  • Coaching Data – any other personal data you may choose to provide to us in connection with the coaching that we deliver to you, including any information about your personal circumstances and lifestyle

If you are a business contact, we may collect the following information about you:

  • Identity Data - full name and title.
  • Contact Data - address, email address and telephone number(s).
  • Financial Data - bank account and payment card details (if you are an individual/sole trader that we have referral arrangements with, which involve us paying referral fees to a personal bank account).

We need this personal data to provide you with access to our website and to provide you with our services. If you do not provide personal data we ask for, it may delay or prevent us from providing the website or our services to you.

Our website is not intended for use by children and we do not knowingly collect or use personal data relating to children.

We do not routinely collect any information about Criminal Conviction and Offences.

Nor do we routinely collect any Special Categories of Personal Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). However on occasion you may choose, at your discretion, to share some special category personal data with us during a coaching session. We will only process this personal data with your explicit consent.   

We may also collect and use Aggregated Data such as statistical or demographic data for our own business purposes. Aggregated Data may be derived from your personal data but is not considered personal data in law as it does not include information that can directly or indirectly identify you.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a lawful basis for doing so, which includes:

  • Contract (only where we contract with you directly, in your capacity as a consumer): where our use of your personal data is necessary to perform a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
  • Legitimate interests: where our use of your personal data is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your privacy rights and freedoms which override our legitimate interests).
  • Legal obligation: where our use of your personal data is necessary for us to comply with the law (not including contractual obligations).
  • Consent: where you have given us clear consent for us to process your personal data for a specific purpose.

The table below explains what we use your personal data for and why, as well as what our legitimate interests are where we are relying on our legitimate interests as the lawful basis to process your personal data:

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

Where you are a recipient of our services to register you as a new customer and/or user on our online coaching portal.

(a) Identity

(b) Contact

(c) Profile

(a) Performance of a contract with you.

(b) Necessary for ours and a third party’s legitimate interests (to set up and manage our website user relationships)

Where you are a recipient of our services, to provide services to you, including:

(a) to deliver coaching services to you

(b) to manage payments, fees and charges

(c) to collect and recover money owed to us

(a) Identity

(b) Contact

(c) Profile

(d) Financial

(e) Transaction

(f) Coaching (including Special Category Personal Data if you choose to divulge this during a coaching session)

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us and to provide our products/services to our paying customers)

If the data is a Special Category of Personal Data we will only process this with you explicit consent.

For all categories of data subject, to manage our relationship with you which will include:

(a) Notifying you about changes to our website, services, terms and conditions, or privacy policy

(b) Asking you to leave a review or take a survey

(c) Responding to queries you may raise

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to manage our customer relationships,  keep our records updated and to study how customers use our services

Where you are a website visitor or online coaching portal user, to administer and protect our business, website and online coaching portal (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

For all categories of data subject, to deliver relevant content and marketing materials to you and measure or understand the effectiveness of the marketing we send to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

(a) Consent, having obtained your prior consent to receiving direct marketing communications

OR

(b) Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)

 

Where you are a website visitor or online coaching portal user, to use data analytics to improve our website, online coaching portal, marketing, customer relationships and experiences

(a) Technical

(b) Usage

(a) Necessary for our legitimate interests (to define types of customers for our services, to keep our website and online coaching portal updated and relevant, to develop our business and to inform our marketing strategy)

OR

(b) Consent, having obtained your prior consent to non-essential cookies or receiving direct marketing communications.

For all categories of data subject, to make suggestions and recommendations to you about services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(a) Consent, having obtained your prior consent to receiving direct marketing communications

OR

(b) Necessary for our legitimate interests (to develop our services and grow our business)

 

Where you are a business contact, to set you up as a referrer and pay you or your business referral fees for referrals made to us 

(a) Identity

(b) Contact

(c) Financial

(a) Performance of a contract with you.

(b) Necessary for ours and a third party’s legitimate interests (to set up and manage our referral relationships)

 

  1.  Who we share your personal data with

We may share your personal data with the third parties set out below for the purposes listed in the above table in the ‘how and why we use your personal data’ section:

  • External third parties we use to help provide our website, online coaching portal and services to you, e.g. Kajabi our online platform provider and Zoom our chosen video call provider, both of which are US companies.
  • Other external third parties we use to help us run our business, e.g. Google our document management and email provider.
  • Our external professional advisors (such as our lawyers or accountants).

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

We may disclose your personal data to law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share personal data with other third parties, such as potential buyers of some or all of our business or during a company re-structuring. Alternatively, we may seek to acquire other business or merge with them. Personal data will be anonymised where possible, but this may not always be possible. The recipient of the personal data will be bound by confidentiality obligations.

  1. Transferring your personal data out of the UK and EEA

To provide our website, online coaching portal and services to you, it is sometimes necessary for us to share your personal data outside the UK or EEA, for example with our service providers that are either located outside the UK or EEA, or that transfer personal data outside of the UK or EEA. This will also be necessary where you yourself are located outside of the UK or EEA.

Transfers of personal data outside of the UK are subject to special rules under UK data protection law. This is because non-UK countries do not have the same data protection laws as the UK.

Transfers of EU personal data outside of the EEA are subject to special rules under EU data protection law. This is because non-EU countries do not have the same data protection laws as the EU.

We will ensure that any transfer of personal data outside of the UK or EEA (as applicable) complies with data protection laws and that all personal data will be secure.

As a result, when we transfer personal data outside of the UK or EEA we will ensure that the transfer complies with data protection laws by following one of the below steps:

  • Confirming that the recipient is located in a country which has been recognised as having an adequate level of protection for personal data (this will include US companies registered with the EU-US Data Privacy Framework and the UK extension to this).
  • Putting in place safeguards (such as approved standard contractual clauses) so that you have enforceable rights and effective legal remedies.
  • Confirming that a specific exception applies under data protection law (we very rarely rely on these specific exceptions though).

For more information about our international transfers, please contact us using the information below.

  1.  Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website and online coaching portal. We use cookies on our website and online coaching portal. Cookies help us recognise you and your device and store some information about your use of our website or online coaching portal. Please see our Cookie Policy for further details.

  1.  Coaching session recordings

From time to time we may ask whether you consent to us recording a coaching session which you are participating in. We will only record your participation in a coaching session with your consent.

You do not have to provide your consent and if you do provide your consent you can withdraw this at any time by contacting us. We will then delete the relevant recording(s).

We will make sure that any session recordings are stored securely.

You can access any recordings that you feature in on request at any time.

  1.  Marketing

We may use your personal data to send you updates (by email, telephone or post) about our services, including exclusive offers, promotions or new services.

You will receive these marketing communications from us if you expressly opted-in to receive them (in which case we rely on your consent), or if it is otherwise in our legitimate interests to send them.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for their marketing purposes.

Regardless of whether you have given your consent to receive marketing communications, or it is in our legitimate interests to send them, you always have the right to opt out of receiving further promotional communications by:

We may ask you to confirm or update your marketing preferences if there are changes in the law, regulation, or the structure of our business.

Please note that we may also send you other communications in relation to your purchase of services (including email and text reminders for coaching sessions) or in order to respond to queries you have raised, such communications are service communications and are not considered a form of marketing communications.

  1.  Your rights

You have the following rights, which you can exercise free of charge:

Access

The right to be provided with a copy of your personal data (the right of access)

Rectification

The right to require us to correct any mistakes in your personal data

To be forgotten

The right to require us to delete your personal data—in certain situations

Restriction of processing

The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object

The right to object:

—at any time to your personal data being processed for direct marketing;

—in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.

Not to be subject to automated individual decision making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

 

For further information about your rights please contact us or see the guidance provided by the UK Information Commissioner’s Office (ICO) on individuals’ rights or if you are located in the EEA, the guidance provided by your local supervisory authority.

If you would like to exercise any of your rights, please:

  • Email, call or write to us — see the 'How to contact us' section at the end of this policy.
  • Let us have enough information to identify you g. your full name and email address.
  • Let us have proof of your identity if requested.
  • Let us know which right you want to exercise and the data to which your request relates.
  1.  How long your personal data will be kept

We will not retain your personal data for longer than necessary for the purposes set out in this privacy policy. Different retention periods apply for different types of personal data.

When it is no longer necessary to retain your personal data, we will delete or anonymise it.

As an indication, if you purchase services from us, we will keep your personal data while we are providing those services. Thereafter, we will keep your personal data for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf.
  • To show that we treated you fairly.
  • To keep records required by law.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

You can request further details of retention periods for different aspects of your personal data by contacting us.

  1.  Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a personal data breach where we are legally required to do so.

  1.  How to complain

Please contact us if you have any query or concern about our use of your data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113

  1.  How to contact us

You can contact us using the contact details below if you have any questions about this privacy policy or the data we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact email address is: [email protected]

  1.  Changes to this privacy policy

This privacy policy was last updated in July 2025. We keep our privacy policy under regular review to make sure it is up to date and accurate. If we change our privacy policy from time to time, we will post the details of any changes here. We may also take reasonable steps to notify you if the changes affect how your personal data is processed.