Privacy Policy

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Positivity in Practice is a trading name of Nickleby Consulting Ltd (Company No. 12164548).

We are the controller of your personal data. For more information on controllers and their responsibilities please see ICO guidance on data protection principles, definitions, and key terms.

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

• Contact details
• What information we collect, use, and why
• Lawful bases and data protection rights
• Our lawful bases for the collection and use of your data
• Where we get personal information from
• Storage, access and use of in-app coaching data
• Storage, access and use of 1-2-1 and group coaching data
• How long we keep information
• Who we share information with
• Sharing information outside the UK
• Cookies and tracking
• How to complain

Contact details

Email: sarah@positivityinpractice.com

What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

• Names and contact details
• Addresses
• Occupation
• Payment details (including card or bank information for transfers and direct debits)
• Usage data (including information about how you interact with and use our website, products and services)
• Records of meetings and discussions
• Account access information
• Coaching session data
• Website user information

We collect or use the following personal information for the operation of client or customer accounts:

• Names and contact details
• Addresses
• Purchase or service history
• Account information, including registration details
• Technical data, including information about browser and operating systems

We collect or use the following personal information for information updates or marketing purposes:

• Names and contact details
• Profile information
• Marketing preferences
• Purchase or account history
• Website and app user journey information
• IP addresses

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 top 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 and improve products and services for clients are:

• Contract – we have to collect or use the information so we can enter into or carry out a contract.

Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:

• Contract – we have to collect or use the information so we can enter into or carry out a contract.

Our lawful bases for collecting or using personal information for information updates or marketing purposes 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.

Where we get personal information from

• Directly from you

Storage, access and use of in-app coaching data

If you interact with the AI coach, your inputs and outputs are processed by third-party AI providers to generate responses. Your data is not used to train AI models.

Our AI providers retain data for a limited period for operational and security purposes (currently up to 30 days), after which it is automatically deleted.

We do not store your coaching conversations. We only store limited information derived from your interactions (such as insights and contextual information) when you specifically select this option in-app, to enable personalised coaching and continuity across sessions. This data is stored securely and is not routinely accessed by us. Access would only occur where necessary, for example where required by law. 

You can view, edit and delete this data at any time within the app.

Storage, access and use of 1-2-1 and group coaching data

Information shared during 1-2-1 or group coaching sessions may be recorded in the form of notes to support the coaching process.

These notes are stored securely and are only accessed by us where necessary to deliver the coaching service. They are not shared with third parties unless required by law.

How long we keep information

We retain information for only as long as is necessary. 

Membership account, app usage data and app coaching data: We retain account information and data generated through use of the app (including insights derived from your interactions with the AI coach to personalise your coaching experience) for as long as your account is active. If you cancel your subscription, this data is deleted within 30 days.

Coaching data: Information acquired or shared during 1-2-1 or Group Coaching sessions will be retained for no more than 24 months or until you request safe destruction of it, whichever is sooner.

Marketing data: We retain marketing preferences and contact details until you unsubscribe, or for up to 24 months after your last interaction with us, whichever occurs first.

Payment and financial data: We retain payment and transaction records for 6 years as required by UK law.

Who we share information with

We share information with third-party data processors only where necessary to operate and deliver our services. These processors act on our instructions and are bound by appropriate data processing agreements.

Sharing information outside the UK

Several of our data processors are based outside the UK, primarily in the United States and the European Union. All such transfers are made in compliance with UK GDPR, using appropriate safeguards such as the UK Addendum to the EU Standard Contractual Clauses or UK Adequacy Regulations as applicable.

Cookies and tracking

Our website and application use essential cookies to operate the site. We may also use analytics cookies to help us understand how users interact with our services. You can control cookies through your browser settings or through our cookie banner.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

Privacy Policy last updated

31st May 2026