UK Privacy Notice

Version 2026-06-07

This notice explains how CLEAR Leadership Coach ("we", "us") collects and uses your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as overseen by the Information Commissioner's Office (ICO).

Who is the data controller

CLEAR Leadership Coach is the controller responsible for your personal data. For any privacy query or to exercise your rights, contact us through the in-app privacy settings.

What we collect, why, and our lawful basis

Data categoryPurposeLawful basisRetention
Account & profile (name, email, age verification)Create and secure your account; verify you are 13+Contract; Legal obligationLife of account; deleted on erasure request
Onboarding answers, purpose & goalsPersonalise your coaching experienceContractLife of account
Daily check-ins, scorecards, reps & receiptsTrack progress and surface patternsContractPer data retention schedule (see below)
Pressure sessions & AI interactionsProvide real-time coaching responsesContract; Consent (for AI processing)Per data retention schedule (see below)
Consent & privacy settingsHonour your data-sharing preferencesLegal obligation; ConsentLife of account; audit record retained
Billing & subscription identifiersProcess payments via our PCI-compliant providerContract; Legal obligationAs required by tax/accounting law

Data retention

We keep personal data only as long as necessary for the purposes above. Activity data (such as check-ins, pressure sessions, and AI interactions) is automatically anonymised or deleted once it exceeds the periods defined in our retention schedule (current version 2026-06-07). You can request earlier erasure at any time.

Age requirement

You must be at least 13 years old to use CLEAR Leadership Coach. We verify age at sign-up and record the verification timestamp.

Your rights under UK GDPR

  • The right to be informed about how your data is used.
  • The right of access to your personal data.
  • The right to rectification of inaccurate data.
  • The right to erasure ("right to be forgotten").
  • The right to restrict processing.
  • The right to data portability.
  • The right to object to processing.
  • Rights related to automated decision-making and profiling.

You can exercise these rights from your privacy settings.

International transfers

Some of our processors are located outside the UK. Where data is transferred internationally, we rely on appropriate safeguards such as the UK International Data Transfer Agreement (IDTA) or Standard Contractual Clauses, with data encrypted in transit and at rest.

Complaints

If you have concerns about how we handle your data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.