Privacy Policy
Last updated: 25 October 2026
This Privacy Policy explains how English Business Coach Academy (“EBC Academy”, “we”, “us” or “our”) collects, uses, stores and protects personal information when you visit our website, submit forms, request a consultation, book coaching sessions, use our learner or coach areas, receive a personalised roadmap, make payments or participate in live coaching sessions.
We aim to process personal information lawfully, fairly and transparently, and to collect only information that is reasonably necessary to provide and administer our services, operate our website, maintain security and comply with legal obligations.
1. Who we are
This website is:
https://academy.englishbusinesscoach.com/
For data protection purposes, the controller responsible for personal information processed in connection with our Academy services is:
- Business or controller name:Tarquin William Bagnall
- Trading name: English Business Coach Academy
- Contact email: info@englishbusinesscoach.com
We determine the purposes and means of processing personal information for our services, except where a third-party provider acts as an independent controller for its own processing.
2. Personal information we collect
The information we collect depends on how you use our website and services. It may include:
- Your full name and email address.
- Information provided when requesting or booking an initial consultation.
- Information submitted through roadmap, diagnostic or learning forms.
- Your professional role, career objectives, learning goals and development requirements.
- Information relating to English-language learning and professional communication.
- Your personalised roadmap, learning activities and session materials.
- Coaching notes, corrections, feedback and information recorded by your coach.
- Information about learning progress and areas for development.
- Session, booking, account and payment-administration information.
- Messages and other information you voluntarily provide.
- Technical information necessary to operate and secure the website, such as login records, IP addresses and browser or device information, where collected.
Please do not provide unnecessary sensitive personal information through our forms, coaching areas or messages. This includes medical, psychological, political, religious, financial or other sensitive information unless it is specifically necessary and there is a lawful basis for processing it.
3. Learner records, coaching notes and learning information
When you use our coaching or learner services, we may maintain a learner record associated with your account. This may contain:
- Your name and contact details.
- Your professional goals and learning objectives.
- Your personalised roadmap and learning priorities.
- Coaching notes, corrections and feedback.
- Session plans, exercises, roleplays and post-session activities.
- Information about your progress and areas for development.
- Session dates, bookings and related administrative information.
- Other information reasonably necessary to deliver and manage your coaching programme.
We use these records to personalise coaching, prepare for sessions, maintain continuity between sessions, track learning progress, update learning materials and provide the services you request.
Access to learner information is restricted according to roles and permissions within our coaching system. Coaches and administrators should access learner information only where reasonably necessary for their role.
Coaches should keep notes relevant to the coaching service and avoid recording unnecessary sensitive personal information.
4. Initial consultation forms
When you submit an initial consultation form, we use the information you provide to:
- Process and respond to your consultation request.
- Arrange and manage the consultation.
- Contact you about the consultation.
- Understand your objectives and requirements.
- Prepare for the consultation and assess whether our services are suitable for your needs.
Information submitted through consultation forms may be retained as part of our business and customer records in accordance with the retention provisions of this Policy.
5. Personalised roadmaps and artificial intelligence
EBC Academy uses artificial intelligence (“AI”) to assist with preparing personalised learning roadmaps and professional-development materials.
Depending on the service and stage of your coaching programme, information processed by AI may include professional goals, role-related information, learning objectives, roadmap details, coach notes, corrections and feedback. This information is used to generate or adapt learning recommendations and materials relevant to your coaching programme.
We use Google’s Gemini API through a paid service for these AI-assisted functions. We configure our system to send information needed for the requested AI task. Depending on the task, this may include learner-specific information and coaching notes. Information may therefore remain personal data even when direct identifiers such as a person’s name or email address are not included in an AI request.
How Google uses AI prompts and responses: Under Google’s published terms for paid Gemini API services, Google does not use prompts and responses submitted through paid services to improve its products. Google may nevertheless process and retain prompts and responses for a limited period for safety, security, compliance and legal purposes. Such data may be stored or processed in countries where Google or its service providers operate. Google’s own terms and data-processing documentation apply to this processing.
We do not intentionally include a learner’s direct identifying details in Gemini requests unless they are necessary for the relevant function. This is a technical and operational safeguard, not a guarantee that all information sent to an AI provider is anonymous.
We use AI assistance to help us:
- Analyse information relating to stated professional and learning objectives.
- Identify potential learning priorities and development areas.
- Generate a proposed personalised roadmap.
- Prepare session plans, learning exercises and roleplay scenarios.
- Use relevant coach notes and corrections to generate post-session activities and subsequent learning materials.
- Adapt materials to the learner’s objectives and coaching progress.
AI-generated roadmaps and recommendations are proposals to support the coaching service, not a final automated judgement about the learner. A roadmap may be presented to the learner before a coach has reviewed it. The learner and coach can then review and discuss the roadmap together and make appropriate changes.
For session materials, the coach reviews and may edit or reject AI-generated content before it is provided to the learner.
We do not intend to use AI to make decisions solely by automated means that produce legal effects or similarly significant effects on you. Our AI-assisted roadmap process does not determine whether you may access our coaching service. AI-generated recommendations do not replace the learner’s or coach’s judgement.
Please do not submit unnecessary sensitive personal information through forms or coaching notes. We take reasonable steps to apply appropriate contractual, technical and organisational safeguards when using third-party AI services.
6. Coaching sessions and learner areas
Our website may provide separate areas for learners and coaches.
The learner area may provide access to your roadmap, learning objectives, session materials, activities, progress information and other content associated with your coaching programme.
The coach area may allow authorised coaches to view relevant learner information, prepare or review learning materials and record coaching notes or corrections necessary to provide the coaching service.
We use access controls and reasonable security measures to restrict access to learner information. Users are responsible for keeping their login credentials confidential and for notifying us if they suspect unauthorised access to their account.
7. Live video coaching sessions — Daily.co
Live coaching sessions are provided using Daily.co video technology.
When you join a live session, Daily.co and the related technical infrastructure may process information necessary to establish and operate the call. Depending on how the session is configured, this may include your display name or user identifier, IP address, device and browser information, connection data and the audio or video transmitted during the session.
We do not routinely record live coaching sessions. Audio, video or screen-sharing content is not intended to be recorded or stored by us through Daily.co unless a recording function is deliberately enabled and the relevant recording process is initiated. If we introduce recording, we will provide appropriate information beforehand about the purpose, legal basis, access arrangements and retention period, and obtain consent where required by law.
Daily.co may process technical data under its own privacy and security arrangements. You can read more here:
8. Google Calendar Integration
If you connect your account or coaching schedule to Google Calendar, English Business Coach (EBC) may request access to your calendar through Google’s APIs. Access is granted through Google’s OAuth authorisation process and is limited to the permissions you approve.
Depending on the permissions granted and the features you use, EBC may:
- Retrieve your list of available Google Calendars so you can select which calendar to connect.
- Check calendar availability and busy periods to help prevent double-booking.
- Create Google Calendar events for coaching sessions booked through EBC.
- Remove the original Google Calendar event created through EBC when a coaching appointment is cancelled or rescheduled.
- Create a new Google Calendar event when a replacement appointment is confirmed following rescheduling.
- Cancel or remove events created through EBC when coaching appointments are cancelled.
Google Calendar information is used to provide the calendar synchronisation and scheduling functionality requested by the connected user. Calendar availability information is used to determine which appointment times are available. Private event details are not displayed to clients.
We do not sell Google Calendar information or use it for advertising purposes.
Google API Data — Limited Use
The use of information received from Google Workspace APIs, including raw and derived data, will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
Google Workspace API data is not used to create, train or improve general-purpose or foundational artificial intelligence or machine learning models.
Although EBC uses Google Gemini for separate coaching features, information obtained from Google Calendar through Google APIs is not shared with Gemini, included in AI prompts, or used as input for AI or machine learning processing. Google Calendar data is used exclusively for the scheduling and calendar synchronisation features described above.
You can revoke EBC’s access through your Google Account security settings. Revoking access may prevent Google Calendar synchronisation and availability-checking features from working.
9. Payments and Stripe
Where you purchase coaching or other paid services, payments may be processed by Stripe.
Payment-card details are processed by Stripe and are not intended to be stored in our WordPress database. We may receive limited transaction information, such as payment status, transaction reference, amount, currency and information needed to associate a payment with the relevant customer or order.
Stripe processes personal information under its own privacy policy and applicable data-processing terms. You can read its Privacy Policy.
10. WordPress and our website systems
Our website operates using WordPress together with our own booking, coaching and learner-management functionality.
Our custom website functionality may store information needed to operate the service, including learner identity and account information, bookings, roadmaps, coaching notes, learning materials and related progress information.
Our primary website and application/database infrastructure is hosted on servers located in London, United Kingdom. We take reasonable technical and organisational measures to protect information stored on our systems against unauthorised access, loss, alteration or disclosure.
11. Cookies and similar technologies
Our website may use cookies and similar technologies for functions such as:
- Keeping you signed in and maintaining secure sessions.
- Remembering necessary preferences.
- Providing booking and learner-area functionality.
- Protecting against fraud, abuse and unauthorised access.
- Understanding website performance and usage where applicable.
Where applicable law requires consent for non-essential cookies or similar technologies, we will request that consent before using them. You can also control cookies through your browser settings. Disabling necessary cookies may prevent some website or learner-area features from functioning correctly.
12. Embedded content and third-party services
Our website may contain links to, or embedded content from, third-party services. Depending on the functionality you use, these may include AI, video-conferencing, payment, calendar, hosting, security and other technology providers.
When you interact with a third-party service or embedded feature, that provider may process information in accordance with its own privacy policy and terms. The provider’s processing may be governed by separate contractual arrangements between us and the provider.
Relevant provider information includes:
13. Who we share information with
We may share personal information with service providers where necessary to operate our website and provide our services. Depending on the features you use, these may include:
- Google / Gemini: AI-assisted roadmap generation and personalised learning materials, including relevant learner information, coach notes and corrections where needed for the task.
- Daily.co: live video coaching sessions and the technical services required to operate them.
- Stripe: payment processing and transaction administration.
- Google Calendar: calendar synchronisation where you choose to connect it.
- Website, hosting and database providers: operating and maintaining our website and application.
- Security and technical service providers: maintaining security, troubleshooting and preventing abuse.
We do not sell your personal information. We do not share learner information with third parties for their own advertising purposes.
We may disclose information where required by law, court order or regulatory authority, or where reasonably necessary to protect our legal rights, users, systems or property.
14. Legal bases for processing
Where the EU General Data Protection Regulation (GDPR), UK GDPR or other applicable data protection legislation applies, we process personal information only where an appropriate legal basis is available.
Depending on the circumstances, the legal basis may include:
- Contract: where processing is necessary to provide coaching, manage your account, arrange sessions or deliver a service you have requested.
- Legitimate interests: where processing is reasonably necessary to operate, secure and administer our services, provided those interests do not override your rights and freedoms.
- Consent: where we ask you to consent to a specific processing activity and consent is the appropriate legal basis.
- Legal obligation: where processing is necessary to comply with applicable law.
Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. It also does not affect processing that relies on a different lawful basis.
15. Marketing communications
We may send service-related communications needed to administer your consultation, coaching programme, account, payments or bookings.
Where consent or another specific legal requirement applies to marketing communications, we will comply with that requirement. You can unsubscribe from marketing communications using the unsubscribe link provided or by contacting us.
Unsubscribing from marketing does not prevent us from sending essential service-related messages.
16. How long we retain your information
We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including providing coaching, maintaining learner records, administering bookings, resolving disputes, maintaining business records and complying with legal obligations.
Active learner information, including roadmaps, coaching notes, corrections and learning materials, may be retained while you receive coaching services and for a period afterwards where necessary for legitimate business, legal or administrative purposes.
Consultation enquiries, account records, booking details, payment-related records and technical logs may be retained for different periods depending on their purpose and any applicable legal requirements.
Google’s retention of Gemini API prompts and responses is governed by Google’s applicable terms and data-processing documentation. Paid Gemini API prompts and responses may be logged for a limited period for safety, security and legal purposes.
When personal information is no longer required, we will take reasonable steps to securely delete or anonymise it, subject to technical limitations, backups and any legal retention obligations.
If you would like information about the retention period applicable to a particular category of your information, please contact us using the details in this Policy.
17. International data transfers
Our primary website and application/database infrastructure is hosted in London, United Kingdom. Some third-party providers may process information in other countries, including countries outside the United Kingdom or European Economic Area.
For example, Google’s Gemini API terms state that prompts and responses submitted through paid services may be stored transiently or cached in countries where Google or its agents maintain facilities. The locations involved may depend on the service and applicable provider arrangements.
Where applicable data protection law requires safeguards for an international transfer, we will take reasonable steps to ensure that an appropriate lawful transfer mechanism and suitable safeguards are in place.
18. Security
We take reasonable technical and organisational measures designed to protect personal information against accidental loss, unauthorised access, alteration or disclosure. Measures may include access controls, authentication, role-based permissions, secure hosting, software updates, backups and other security measures appropriate to our systems.
Access to learner records and coaching notes should be limited to authorised people who need the information to perform their role. We also seek to limit the information sent to third-party services to what is reasonably necessary for the relevant function.
No website, database or internet transmission can be guaranteed to be completely secure. If you believe your account has been compromised, please contact us promptly.
19. Your data protection rights
Depending on the law that applies to you and the circumstances of the processing, you may have the right to:
- Request access to personal information we hold about you.
- Request correction of inaccurate or incomplete information.
- Request deletion of personal information in certain circumstances.
- Request restriction of processing in certain circumstances.
- Object to processing based on legitimate interests or to direct marketing, where applicable.
- Withdraw consent where processing is based on consent.
- Receive certain personal information in a portable format.
- Complain to the relevant data protection supervisory authority.
These rights are subject to applicable legal conditions and exceptions. To exercise your rights, contact us using the details in this Policy. We may need to verify your identity before responding.
If you are in Spain, you can find information about making a complaint with the Spanish Data Protection Agency (AEPD) at https://www.aepd.es/.
20. Deleting your information
You may request deletion of personal information that we hold about you.
Where legally permitted and technically possible, we will delete or anonymise information that we no longer have a legitimate or legal reason to retain. Some information may need to be retained to comply with legal obligations or to establish, exercise or defend legal claims.
Deleting your learner record may mean that we can no longer provide certain coaching, learner-area or historical progress features. Deletion from our systems does not automatically mean that every record held independently by a third-party provider or contained in a backup has been immediately erased.
21. Children’s privacy
Our services are designed primarily for adult learners and professionals. Our Gemini API integration is subject to Google’s applicable age and use restrictions. We do not knowingly seek to collect personal information from children in circumstances where doing so would be prohibited by applicable law or the relevant service terms.
If you believe a child has provided personal information to us inappropriately, please contact us so that we can investigate and take appropriate action.
22. AI and automated processing
AI supports the delivery of personalised learning and coaching materials. It may process professional goals, learning objectives, roadmap information, coaching notes, corrections and feedback to generate or adapt:
- Personalised learning roadmaps and recommendations.
- Session plans, exercises and roleplay scenarios.
- Post-session activities and further learning materials.
AI-generated content may be inaccurate, incomplete or unsuitable for a particular context. It is used as assistance within a human-led coaching service, not as a substitute for professional judgement.
The initial roadmap may be shown to the learner before the coach has reviewed it. The learner and coach can review and discuss it together. Session materials generated from the roadmap or coaching notes are reviewed and may be edited by the coach before being provided to the learner.
We do not intend to use AI to make solely automated decisions that produce legal or similarly significant effects on you, or to determine whether you are allowed to access our coaching service. The AI-assisted process is designed to support learning recommendations and preparation, rather than to make binding decisions about a learner.
We provide information about our use of AI so that learners understand where AI contributes to their learning materials. We also aim to maintain appropriate human oversight and safeguards in the operation of these features.
If you have questions about the use of AI in your coaching programme or about the information processed for an AI-assisted task, please contact us.
23. Information you submit through forms
Before submitting information through one of our forms, please ensure that it is accurate and that you are comfortable providing it for the purpose explained by the relevant form.
You should not submit information about another person unless you are authorised to do so and have a lawful basis for providing it. Please do not submit unnecessary passwords, payment-card details, medical information or other highly sensitive information through our forms or coaching areas.
Coaches should keep notes relevant to the coaching service and avoid entering unnecessary sensitive or confidential information into AI-assisted features.
24. Consent and form submissions
Where a form asks you to acknowledge this Privacy Policy, that acknowledgement confirms that the Policy has been made available to you. Acknowledgement of a privacy notice is not, by itself, consent to every type of processing described in it.
Where applicable law requires separate consent for a particular activity, such as certain marketing communications, non-essential cookies or recording a coaching session, we will request that consent separately.
Consent to marketing is not required to request a consultation or use our coaching services. Where processing is necessary to perform a coaching contract or relies on another lawful basis, it does not depend on consent unless consent is specifically required by law.
25. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes to our services, technology, third-party providers, legal requirements or data-processing practices.
When we make significant changes, we will take reasonable steps to bring the updated Policy to your attention. The date at the top of the Policy indicates when it was last updated.
26. Contact us
If you have questions about this Privacy Policy, wish to exercise your data protection rights or have concerns about how your personal information is processed, please contact us:
English Business Coach Academy
Controller: Tarquin William Bagnall
Email: info@englishbusinesscoach.com
We will consider and respond to requests in accordance with applicable data protection law.