Version 1.1. Last updated: 19/10/2026
This privacy notice provides you with details of how we collect and process your personal data through your use of our site https://thesharpenedleader.com.
Our services are intended for adults. By providing us with your data, you warrant to us that you are over 18 years of age.
Zest Productivity Ltd, trading as The Sharpened Leader®, is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
If you are a coaching client, our separate Client Privacy Notice covers your coaching, including session recording, transcription and our use of AI. If you are attending a talk, workshop or training day, the terms of that booking cover the event.
Full name of legal entity: Zest Productivity Ltd, trading as The Sharpened Leader® Registered in: England and Wales, company number 16189210 Registered office: The Orchard, Airedale Enterprise, Sunderland Street, Keighley, West Yorkshire, BD21 5LE Email address: jasmine@thesharpenedleader.com ICO registration number: ZB856000
We have not appointed a Data Protection Officer. We are not required to do so, and you can raise any privacy matter with us using the details above.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at jasmine@thesharpenedleader.com.
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you.
This includes any communication that you send to us, whether through the contact or enquiry form on our website, through email, text, WhatsApp, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping, and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests, which in this case are to reply to communications sent to us, to keep records, and to establish, pursue or defend legal claims.
This includes data relating to any purchase of our services, such as your name, title, billing address, email address, phone number, contact details, purchase details and payment details. We process this data to supply the services you have purchased and to keep records of those transactions. Our lawful ground for this processing is the performance of a contract between you and us, and taking steps at your request to enter into such a contract.
We do not store your card or bank details. Payments are handled by our invoicing, banking and card payment providers, who process your payment information under their own terms. Where you pay by card, your card details go directly to our card payment provider and we never see or hold them.
This includes data about how you use our website and any online services, together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups, and to enable publication and administration of our website, our other online services and our business. Our lawful ground for this processing is our legitimate interests, which in this case are to enable us to properly administer our website and our business.
This includes data about your use of our website and online services, such as your IP address, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings, and other technology on the devices you use to access our website. The source of this data is our website platform and our analytics tracking system. We process this data to analyse your use of our website, to administer and protect our business and website, to deliver relevant website content to you, and to understand the effectiveness of our marketing.
Our lawful ground for this processing is our legitimate interests, which in this case are to enable us to properly administer our website and our business, to grow our business, and to decide our marketing strategy. Where cookies or similar technologies are used to collect this data and your consent is required, we rely on that consent. See our cookie policy for details.
We also count visits to our website using Burst Statistics, which runs on our own website and does not use cookies or store anything on your device. It uses an anonymous code that changes every day, so we cannot recognise you across days or identify you personally, and it gives us only overall figures such as the number of visits, the pages viewed and where visitors came from. The data stays on our website, is not shared with anyone else and is not used for advertising. Our lawful ground for this processing is our legitimate interests, which in this case are to understand how our website is used and to improve it. If you would prefer not to be counted, you can switch on the “Do Not Track” setting in your web browser, or email us at Jasmine@Thesharpenedleader.Com.
This includes data about your preferences in receiving marketing from us and your communication preferences, including your name, email address and any information you give us when you download a free resource or subscribe to our emails. We process this data to send you our email newsletter and information about our services, and to measure and understand the effectiveness of that communication.
Our lawful ground for this processing is either your consent or our legitimate interests, which in this case are to grow our business and to carry out direct marketing. Where we rely on legitimate interests, we have carried out a balancing assessment and concluded that our interest in growing our business does not override your rights and freedoms. You can object or opt out at any time. Where the Privacy and Electronic Communications Regulations require your consent, we obtain it.
This includes information you choose to give us when you enquire about coaching, book a discovery or diagnostic call, or complete a pre-session questionnaire or diagnostic. This may include your role, your organisation, what you want to work on, and your own account of the challenges you are facing. We process this data to respond to your enquiry, to assess whether our services are a good fit, and to prepare for any call. Our lawful ground for this processing is our legitimate interests, which in this case are to respond to enquiries and to decide whether to enter into a contract with you, and, where you go on to purchase, taking steps at your request to enter into a contract.
We may also use communication data, customer data, user data, technical data, marketing data and enquiry data for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests, which in this case are to establish, pursue or defend legal claims.
Where we are required to collect personal data by law, or under the terms of the contract between us, and you do not provide us with that data when requested, we may not be able to perform the contract. If you do not provide us with the requested data, we may have to cancel a service you have ordered, and if we do, we will notify you at the time.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We will only use your personal data for a purpose it was collected for, or a reasonably compatible purpose if necessary. For more information on this please email us at jasmine@thesharpenedleader.com. If we need to use your details for an unrelated new purpose, we will let you know and explain the legal grounds for processing.
Sensitive data, also called special category data, refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.
We do not ask you to provide sensitive data through our website, and we ask you not to include it in enquiry forms or free-text fields.
If you become a coaching client, the nature of coaching means that you may choose to share information that counts as sensitive data during our work together. That processing is explained in full in our Client Privacy Notice, which we provide to you before your first session, together with a separate request for your explicit consent. Nothing in this website notice is a request for that consent, and nothing in it operates as your consent.
If you do volunteer sensitive data through the website before that point, for example in a free-text enquiry message, we will use it only to respond to you and to decide whether our services are appropriate, and we will delete it or remove it from our enquiry records as soon as we no longer need it for that purpose. Where we retain any of it, our condition for doing so is that the processing is necessary for the establishment, exercise or defence of legal claims.
We do not collect any information about criminal convictions and offences.
We do not make decisions about you that produce legal effects concerning you, or that similarly significantly affect you, using solely automated means. Every decision that affects you, including whether we take you on as a client, is made by a person.
We use automated processes and artificial intelligence tools to assist us in running our business. This means that we may use software to analyse personal data in order to help us work more efficiently.
These automated processes are used for purposes such as:
These processes do not have a legal or similarly significant effect on you. They support our internal processes and do not materially affect your rights, opportunities or access to services. No AI-generated output that concerns you individually is sent to you, or acted on in a decision about you, without being reviewed by a person first.
Where these tools are used in the delivery of coaching, they are described in more detail in our Client Privacy Notice.
We collect data about you when you provide it to us directly, for example by filling in forms on our site, subscribing to our emails, downloading a free resource, booking a call, or sending us an email or message.
We automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this: https://thesharpenedleader.com/cookie-policy.
We may also receive data about you from:
Our lawful ground for processing your personal data to send you marketing communications is either your consent or our legitimate interests, namely to grow our business and to carry out direct marketing. Where we rely on legitimate interests, we carry out a balancing assessment first.
Under the Privacy and Electronic Communications Regulations (PECR), we may send you marketing communications from us if you made a purchase or asked for information from us about our services, or you agreed to receive marketing communications, and in each case you have not opted out of receiving such communications since.
PECR’s consent rule applies to individual subscribers. Where you are a corporate subscriber, such as a limited company or a limited liability partnership, we may send you marketing emails without your prior consent. We still need a lawful ground under the UK GDPR to process the personal data of a named individual at that organisation, and you can object or opt out at any time.
We use the Meta Pixel on our website. This is a small piece of code that tells Meta when you have visited our site or taken an action on it, so that we can understand how our advertising performs and, where relevant, show you our content on Facebook and Instagram. For the data the pixel collects, we and Meta act as joint controllers. The pixel only runs where you have accepted marketing cookies, and you can change that at any time through our cookie settings. Meta’s own privacy policy explains what it does with the data it receives.
Other than through the Meta Pixel as described above, we will never share your personal details with any third party for their own marketing purposes.
You can ask us to stop sending you marketing messages at any time by following the unsubscribe link on any marketing message sent to you, or by emailing us at jasmine@thesharpenedleader.com.
If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided as a result of other transactions, such as purchases of our services.
We name our main providers so that you can see exactly who processes your data, in what role, and on what safeguard.
|
Provider |
What they do for us |
Their role |
Where data is processed |
Transfer safeguard |
|---|---|---|---|---|
|
GoDaddy (GoDaddy.com, LLC) |
Hosting our WordPress website and our domain names, including contact and enquiry form submissions |
Our processor |
The United States |
UK-US Data Bridge, with Standard Contractual Clauses and the UK Addendum where the Data Bridge does not apply |
|
Meta Platforms (Facebook and Instagram) |
The Meta Pixel on our website, which measures how our advertising and content performs |
Joint controller with us for the data the pixel collects |
Ireland and the United States |
UK-US Data Bridge |
|
MailerLite (MailerLite Limited, Ireland) |
Email marketing, our newsletter and free resources |
Our processor |
European Union |
UK adequacy, no restricted transfer |
|
Google Workspace (Google Cloud EMEA Limited, Ireland) |
Email, calendar, documents and file storage |
Our processor |
European Union, the United States and other countries where Google operates |
Standard Contractual Clauses with the UK Addendum |
|
Zoom (Zoom Communications, Inc.) |
Video meetings, recording, transcription and AI meeting summaries |
Our processor |
Germany for new recordings and transcripts; the United States for account and operational data |
UK-US Data Bridge, and Standard Contractual Clauses with the UK Addendum under Zoom’s data processing agreement |
|
Anthropic (Anthropic Ireland Limited) |
The Claude AI assistant, used to help us draft, analyse and organise our work |
Independent controller, not our processor |
The United States |
Standard Contractual Clauses with the UK Addendum |
|
Calendly (Calendly LLC) |
Booking and scheduling calls |
Our processor |
The United States |
Standard Contractual Clauses with the UK Addendum |
|
Intuit (QuickBooks) |
Invoicing and accounting |
Our processor |
The United States |
Standard Contractual Clauses with the UK Addendum |
|
Stripe (Stripe Payments UK Ltd) |
Card payment processing, where you pay by card |
Independent controller for payment and fraud prevention purposes |
The United Kingdom, the European Union and the United States |
UK-US Data Bridge, and Standard Contractual Clauses with the UK Addendum |
|
Doist (Todoist) |
Task and project management |
Our processor |
The United States |
Standard Contractual Clauses with the UK Addendum |
|
Monzo Bank |
Business banking and payments |
Independent controller under its own regulatory obligations |
The United Kingdom |
Not applicable |
We also share personal data with:
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. Where a provider acts as our processor, we have a written data processing agreement with them and we only allow them to process your personal data for specified purposes and in accordance with our instructions.
Anthropic is a special case. When we use the Claude AI assistant, Anthropic Ireland Limited acts as an independent controller of the data we input, rather than as our processor. That means Anthropic handles that data under its own terms rather than purely on our instruction. We are deliberate about what we put into it, and we have turned off the setting that would allow our inputs to be used to improve Anthropic’s models. Our Client Privacy Notice explains what we do and do not input from coaching sessions.
We are subject to the provisions of the UK General Data Protection Regulation (UK GDPR), which protect your personal data. Some of our providers are based outside the United Kingdom, so using them involves transferring your data internationally.
Where we transfer your data outside the UK, we ensure that safeguards are in place to give your personal data a similar degree of protection. The specific safeguard for each provider is shown in the table in Section 7. In summary, we rely on:
If none of the above safeguards is available for a particular transfer, we may request your explicit consent to it. You will have the right to withdraw this consent at any time.
We have set our Zoom account so that new cloud recordings and live transcripts are stored in Germany, which is covered by UK adequacy. Our Zoom account itself is provisioned in the United States and this cannot be changed on our plan, so account data and operational data are held there. The United Kingdom is not an available storage region on our plan.
Zoom acts as our processor under its data processing agreement, which incorporates the Standard Contractual Clauses and the UK Addendum. Zoom’s terms state as a contractual commitment that Zoom does not use customer content to train its models.
Zoom’s AI features, including meeting summaries, run on Zoom’s default configuration, under which customer content may be processed by third-party AI model providers in the United States. Zoom publishes the current list of these providers at https://www.zoom.com/en/trust/subprocessors/, which at the date of this notice names Anthropic, OpenAI and Perplexity. Those providers act as Zoom’s sub-processors under Zoom’s own agreements with them. We are keeping this arrangement under review and will update this notice if it changes. Our Client Privacy Notice sets this out in full for coaching clients.
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed without authorisation. These include multi-factor authentication on our accounts where the provider supports it, encrypted storage, device encryption, and access controls that limit who can see what.
We are a small business, and Jasmine Clarke is the only person with routine access to client records. Where anyone else is engaged to support the business, they are bound by written confidentiality and data protection terms and are given access only to what they need.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
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.
When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, the potential risk of harm from unauthorised use or disclosure, the processing purposes, whether these can be achieved by other means, and legal requirements.
Our retention periods are:
|
Data |
How long we keep it |
|---|---|
|
Enquiries that do not become clients |
12 months from our last contact with you |
|
Session recordings, transcripts and AI meeting summaries |
Deleted 30 days after the session. Our provider permanently removes them from its systems within a further 30 days |
|
Coaching notes and session summaries |
7 years after the end of the coaching engagement |
|
Consent records |
7 years after the consent is withdrawn or the engagement ends, whichever is later, so that we can demonstrate consent was given |
|
Contracts, invoices and financial records |
6 years after the end of the accounting period they relate to |
|
Marketing list data |
Until you unsubscribe, after which we keep a minimal suppression record so that we do not contact you again |
|
Website analytics data |
In line with the retention settings of our website and analytics providers |
For tax and company law purposes, the law requires us to keep basic information about our customers, including contact, identity, financial and transaction data, for six years after the end of the accounting period to which it relates.
In some circumstances we may anonymise your personal data for research or statistical purposes, in which case we may use that information indefinitely without further notice to you.
Under data protection laws you have rights in relation to your personal data. These include the right to request access, correction, erasure, restriction and transfer, the right to object to processing, the right to portability of data, and, where the lawful ground of processing is consent, the right to withdraw consent.
If you are within the UK, you can see more about these rights at: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/
If you wish to exercise any of the rights set out above, please email us at jasmine@thesharpenedleader.com.
You will not have to pay a fee to access your personal data, or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request, to speed up our response.
When responding to a request to access your personal data, we are only required to carry out searches that are reasonable and proportionate in the circumstances, as expressly recognised in the Data (Use and Access) Act 2025. This means we will take into account factors such as the nature of the information sought, the context in which it is held, any difficulty involved in locating it, and the potential benefit to you of receiving it.
We try to respond to all legitimate requests within one month of receiving the request, or, where applicable, of receiving the identity verification information or clarification we have asked for. The response period is paused, or stopped, while we wait for that information, in line with the Data (Use and Access) Act 2025.
Occasionally it may take us longer than one month if your request is particularly complex, or if you have made a number of requests, in which case we may extend the response period by up to a further two months. We will notify you within one month of receiving your request if an extension is needed, and explain why.
Some rights are not absolute. Where we hold records to meet a legal obligation, or to establish, exercise or defend a legal claim, we may not be able to delete them on request. We will always explain our reasoning rather than simply refusing.
If you have a complaint about how we handle your personal data, we ask that you contact us first so that we can try to resolve it for you.
You can submit a data protection complaint to us by:
We will acknowledge your complaint within 30 days of receiving it. We will investigate your complaint without undue delay, keep you informed of our progress, and communicate the outcome to you clearly, with sufficient detail for you to understand how we reached our conclusion.
If you are not satisfied with our response, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at www.ico.org.uk or by calling 0303 123 1113.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, and to change your preferences, please see our cookie policy: https://thesharpenedleader.com/cookie-policy.
We keep this notice under review and will update it when what we do changes. The version number and date are at the top. Where a change is significant, we will draw it to your attention rather than relying on you to notice.
The Sharpened Leader® jasmine@thesharpenedleader.com · +44 7886 925175 · thesharpenedleader.com
The Sharpened Leader® is a trading name of Zest Productivity Ltd. Registered in England, company number 16189210. Registered office: The Orchard, Airedale Enterprise, Sunderland Street, Keighley, West Yorkshire, BD21 5LE
