Privacy Notice

CLEAR Leadership Coach is built on a philosophy of empowerment, not dependency — and that extends to your data. This notice explains what personal data we process, why, on what lawful basis, how long we keep it, and the rights you have. It is written to meet the transparency requirements of the UK GDPR and the guidance of the UK Information Commissioner's Office (ICO), alongside CCPA/CPRA rights for U.S. residents.

Who we are (data controller)

CLEAR Leadership Coach is the controller responsible for your personal data. If you have any questions about this notice or wish to exercise your rights, contact us through the in-app support page.

What we collect

Account details (email, display name), the onboarding context you choose to share, your daily check-ins, tasks, reps, pressure sessions, scorecards, recaps, playbook entries, AI interaction history, consent settings, and basic technical/usage data needed to run the service securely.

How we use it and our lawful basis

We process your data on the following lawful bases:

  • Contract — to deliver your daily coaching rhythm, store your entries, and provide the features of your account.
  • Consent — to generate AI coaching from your content, and to share your progress with your coach or admin. You can withdraw consent at any time in your privacy settings.
  • Legitimate interests — to keep the service secure, prevent abuse, and improve reliability, balanced against your rights.
  • Legal obligation — to keep limited records (e.g. audit logs of privacy actions) where the law requires.

We collect only the data needed for these purposes (data minimisation) and do not reuse it for incompatible purposes (purpose limitation).

How long we keep it (retention)

We keep your personal data only for as long as your account is active and as needed for the purposes above. Transient operational data (such as older check-ins, AI interaction history, and activity logs) is automatically deleted on a recurring retention schedule. When you delete your account, your personal data is permanently erased, except limited compliance records we are required to retain.

Security

We secure your data in transit (HTTPS) and at rest (encrypted storage). Access is restricted by row-level security so you can only access your own data, and coach/admin access requires your explicit consent.

Your rights

Under the UK GDPR you have the right to access, rectify, erase, restrict, and port your data, and to object to processing. You may also withdraw consent at any time. You can request an export or deletion of your data and manage all sharing in your privacy settings. California residents can exercise their Do Not Sell or Share rights, which we also honour automatically via the Global Privacy Control (GPC) browser signal. We never sell your personal information.

Complaints

If you have a concern, please contact us first so we can help. You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

Age requirement

You must be at least 13 years old to create an account. We verify age at sign-up and do not knowingly process data from children under 13.