Privacy Policy

---

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 7 days), after which it is automatically deleted.

We only store limited information derived from your interactions (such as insights and contextual information) 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 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 the following data processors for the stated activities. 

• Anthropic: They provide AI-powered coaching functionality by processing user inputs to generate responses within the app.
• Supabase: They host and manage our application database, including user account information, coaching data, and other content generated within the app.
• Vercel: They host and deliver our web application and may process technical data such as IP addresses and usage logs to ensure performance and security.
• Mux: They host and stream video content within our application and may process technical data such as device information and viewing behaviour.
• Mem0: They store and manage structured information derived from user interactions to enable personalised coaching and continuity across sessions.
• Stripe: They process online payments, manage subscriptions, and handle billing-related data.
• Brevo: They provide our CRM and email marketing services, including managing contact lists and sending communications.
• OneSignal: They deliver in-app and push notifications and may process device identifiers and notification preferences.
• Resend: They provide transactional email delivery services, including sending account-related communications such as sign-up confirmations and login links.
• Microsoft 365: They host and manage our email communications and cloud-based business tools.
• Zoom: They host online meetings and virtual sessions.
• GoDaddy: They host our website and support its functionality.

Sharing information outside the UK

Where necessary, our data processors will share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

Organisation name: Anthropic

Category of recipient: Artificial intelligence service provider (cloud-based data processor providing AI-powered text generation)

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

Organisation name: Supabase

Category of recipient: Database hosting and backend infrastructure provider

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

Organisation name: Stripe

Category of recipient: Payment processor

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

Organisation name: Vercel

Category of recipient: Cloud hosting and infrastructure provider

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

Organisation name: OneSignal

Category of recipient: Push notification and messaging service provider

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

Organisation name: Resend

Category of recipient: Email delivery and communications service provider

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

Organisation name: Mux

Category of recipient: Video hosting and streaming infrastructure provider

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

Organisation name: Mem0

Category of recipient: Data processing and storage provider supporting AI personalisation

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

Organisation name: Brevo

Category of recipient: CRM and email marketing services

Country the personal information is sent to: France / EU (plus possible global subprocessors)

How the transfer complies with UK data protection law: Adequacy Regulations

Organisation name: Microsoft 365

Category of recipient: Email and cloud service provider

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

Organisation name: Zoom Video Communications

Category of recipient: Video conferencing and online meeting provider

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

Organisation name: GoDaddy

Category of recipient: Website hosting provider

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

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

13th April 2025

This privacy notice was based on the ICO privacy notice generator.