Privacy policy
Alidade Haven Ltd trading as Martha Lawton customer privacy notice
This privacy notice tells you what to expect us to do with your personal information.
· What information we collect, use, and why
· Lawful bases and data protection rights
· Where we get personal information from
· How long we keep information
· Who we share information with
· Sharing information outside the UK
Contact details
Telephone
02045769434
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
· Gender
· Pronoun preferences
· Occupation
· Date of birth
· Marital status
· Third party information (such as family members or other relevant parties)
· Payment details (including card or bank information for transfers and direct debits)
· Financial data (including income and expenditure)
· Transaction data (including details about payments to and from you and details of products and services you have purchased)
· Usage data (including information about how you interact with and use our website, products and services)
· Employment details (including salary, sick pay and length of service)
· Credit history and credit reference information
· Health information (such as medical records or health conditions)
· Criminal records data (including driving or other convictions)
· Information relating to compliments or complaints
· Video recordings
· Audio recordings (eg calls)
· Records of meetings and decisions
· Account access information
· Website user information
· Coaching data, which encompasses anything that coach (or in many cases coachee) can set up within CoachAccountable to support, document, or communicate within a coaching relationship, including but not limited to: - Action items - Metrics and data - Worksheets - Session Notes - Journal Entries - File uploads, links and embedded media - Whiteboards - Appointments and calendar data feeds - Templates - Courses - Other in-app settings - Data from connected 3rd party apps
We may also collect or use the following special category information to provide and improve products and services for clients. This information is subject to additional protection due to its sensitive nature:
· Racial or ethnic origin
· Religious or philosophical beliefs
· Trade union membership
· Health information
· Sexual orientation 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
· Information used for security purposes
· Marketing preferences
· 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
· Addresses
· Profile information
· Marketing preferences
· Purchase or account history
· Website and app user journey information
· IP addresses
We may also collect or use the following special category information for information updates or marketing purposes. This information is subject to additional protection due to its sensitive nature:
· Health information
· Sexual orientation information
We collect or use the following personal information for research or archiving purposes:
· Names and contact details
· Addresses
· Purchase or client account history
· Website and app user journey information
· IP addresses
· Coaching outcomes Course completion rates and learning outcomes
We may also collect or use the following special category information for research or archiving purposes. This information is subject to additional protection due to its sensitive nature:
· Racial or ethnic origin
· Religious or philosophical beliefs
· Health information
· Sexual orientation information
We collect or use the following personal information to protect client welfare:
· Names and contact information
· Client account information
· Health and wellbeing information
We may also collect or use the following special category information to protect client welfare. This information is subject to additional protection due to its sensitive nature:
· Racial or ethnic origin
· Religious or philosophical beliefs
· Health information
· Sexual orientation information
We collect or use the following personal information for dealing with queries, complaints or claims:
· Names and contact details
· Addresses
· Payment details
· Account information
· Purchase or service history
· Call recordings
· Customer or client accounts and records
· Financial transaction information
· Correspondence
We may also collect or use the following special category information for dealing with queries, complaints or claims. This information is subject to additional protection due to its sensitive nature:
· Racial or ethnic origin
· Religious or philosophical beliefs
· Health information
· Sexual orientation information
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:
· 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.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for the operation of client or customer accounts 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.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
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.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for research or archiving purposes:
· 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.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information to protect client welfare 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.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims 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.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Where we get personal information from
· Directly from you
· Third parties:
· In the course of the coaching relationship, clients may share information that they consider to be relevant about other people, including, but not limited to, family members, intimate partners, friends, other members of their household, employers and colleagues. This means that the client is the third party giving limited information to the coach about these people, whose data is held for the benefit of the client in order for the coach to provide them with the coaching service. We do not actively seek to obtain information from third parties beyond this.
How long we keep information
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Who we share information with
Data processors
Google LLC
This data processor does the following activities for us: This data processor provides cloud services and as such they provide telephone and email services, as well as the ability to create and/or store and/or share files including, but not limited to, documents, spreadsheets, presentations, images, video and audio files.
CoachAccountable LLC
This data processor does the following activities for us: They provide coaching client relationship management and coaching tools and also appointment scheduling for non-coaching professional contacts. The tools they provide include but are not limited to appointment scheduling, invoicing, contract management, coaching records, messaging services, online learning, appointment reminders by email and/or SMS. They also provide tools to aggregate certain data to provide business reporting for service improvement purposes.
Microsoft Ireland Operations Ltd
This data processor does the following activities for us: This data processor provides cloud services and as such they provide email services and remote meeting software, as well as the ability to create and/or store and/or share files including, but not limited to, documents, spreadsheets, presentations, images, video and audio files.
Stripe LLC
This data processor does the following activities for us: process payments, keep records of these payments.
A note about PayPal
From time to time we may use PayPal as a payment processor. PayPal is not a data processor, see below.
From PayPal’s own privacy hub: “For most of our products like Hyperwallet, Zettle, and Braintree, PayPal is a data controller when it comes to processing consumer data. Each independently operates, obtains and processes customer information separately from each other. We've included provisions in our agreements with you that address the relationship as independent controllers.
“Neither PayPal nor you as a merchant process personal data on behalf of the other in the normal course of business. However, PayPal does process data received from the customer for purposes of facilitating the payment in the manner determined by PayPal and on the instruction of the customer, which is detailed in our privacy statement.”
QuickBooks (Intuit Inc)
This data processor does the following activities for us: creating and maintaining accounting records, generating and sending accounting documents to customers and suppliers as required. Generating financial reports.
MailChimp (Intuit Inc)
This data processor does the following activities for us: sends marketing emails and records data regarding the response rate to these campaigns. Automates processes relating to subscription and un-subscription from mailing lists.
Squarespace Inc
This data processor does the following activities for us: hosts our website which includes our customer contact forms and newsletter sign-up mechanism.
Zoom
This data processor does the following activities for us: provides remote meeting software and the ability to save assets associated with these meetings such as recordings, notes, chat records, and call transcripts.
Fathom
This data processor does the following activities for us: provides transcription, summaries, video and audio recordings of remote meetings held on Zoom.
MyFinanceFuture
This data processor does the following activities for us: creates cashflow forecasts based on client financial data, for educational purposes, to facilitate clients ability to make effective financial plans for themselves.
Atlassian Pty Ltd (Trello)
This data processor does the following activities for us: this is a legacy system storing client coaching records from before the move to CoachAccountable.
Money Habitudes
This data processor does the following activities for us: assessment of financial habits and attitudes for the purposes of financial coaching.
Others we share personal information with
· Professional or legal advisors
· Organisations we’re legally obliged to share personal information with
· Publicly on our website, social media or other marketing and information media (with explicit consent)
· Suppliers and service providers
· Professional consultants
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: Google LLC
Category of recipient: Cloud services
Country the personal information is sent to: Various
How the transfer complies with UK data protection law: Google LLC states that it complies with these legal frameworks.
Organisation name: CoachAccountable LLC
Category of recipient: Coaching practice management software
Country the personal information is sent to: United States of America
How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)
Organisation name: Microsoft Ireland Operations Limited
Category of recipient: Cloud services
Country the personal information is sent to: Various
How the transfer complies with UK data protection law: Microsoft Ireland Operations Ltd states that it complies with UK data protection law using a variety of legal mechanisms and safeguards.
Organisation name: Stripe LLC
Category of recipient: Payment processor
Country the personal information is sent to: Various
How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)
Organisation name: Intuit Inc (QuickBooks and MailChimp)
Category of recipient: Accounting and email marketing
Country the personal information is sent to: Various
How the transfer complies with UK data protection law: Intuit Inc states that it complies with UK data protection law using a variety of legal mechanisms and safeguards.
Organisation name: Squarespace Inc
Category of recipient: web hosting
Country the personal information is sent to: Various
How the transfer complies with UK data protection law: Squarespace Inc states that it complies with UK data protection law using a variety of legal mechanisms and safeguards.
Organisation name: Zoom Communications Inc
Category of recipient: virtual meeting
Country the personal information is sent to: Various
How the transfer complies with UK data protection law: Zoom Communications Inc states that it complies with UK data protection law using a variety of legal mechanisms and safeguards.
Organisation name: Fathom Video Inc
Category of recipient: Meeting recording, transcription and note-taking
Country the personal information is sent to: United States of America and possibly various others
How the transfer complies with UK data protection law: Fathom Video Inc states that it complies with UK data protection law using a variety of legal mechanisms and safeguards
Organisation name: MyFinanceFuture Ltd
Category of recipient: Financial planning and cashflow forecasting
Country the personal information is sent to: Various
How the transfer complies with UK data protection law: MyFinanceFuture Ltd states that it complies with UK data protection law using a variety of legal mechanisms and safeguards
Organisation name: Atlassian Pty Ltd (Trello)
Category of recipient: Coaching notes storage (legacy system)
Country the personal information is sent to: Various
How the transfer complies with UK data protection law: Atlassian Pty Ltd states that it complies with UK data protection law using a variety of legal mechanisms and safeguards
Organisation name: Money Habitudes LLC
Category of recipient: specialist financial coaching assessment
Country the personal information is sent to: Various
How the transfer complies with UK data protection law: Money Habitudes LLC states that it complies with UK data protection law using a variety of legal mechanisms and safeguards
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.
The ICO’s address:
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
Last updated 6th May 2026