Legal
Privacy policy
This policy explains what personal data Integrity Studio Co. ("we", "us", "our") collects when you use integritystudioco.com or engage our services, how we use it, who we share it with, and the rights you have under UK data protection law.
Integrity Studio Co. Ltd · Version 0.1 (draft for legal review) · Last updated: May 2026
Draft notice: This is a working draft prepared from a website-compliance checklist. It is being reviewed before launch — content is accurate to our current practice but may be refined by our legal advisor.
1. Who we are
Integrity Studio Co. Ltd is the data controller for personal data collected through this website and our services.
- Company: Integrity Studio Co. Ltd
- Registered in: England and Wales, company number 12746565
- Registered office: 124 City Road, London, EC1V 2NX, United Kingdom
- Email: hello@integritystudioco.com
- Phone: +44 (0)7790 008610
- Website: integritystudioco.com
- VAT status: not currently VAT-registered.
- Professional accreditations: iEQ9 Integrative Enneagram Accredited Practitioner; ICF credentialed coach (awaiting registration); BSI ISO 27001; BSI ISO 9001; CIMA.
2. What personal data we collect
We only collect data that is necessary for us to deliver our services or operate our website. Depending on how you interact with us, this may include:
- Identity and contact data: your name, email address, telephone number, organisation, and (for corporate engagements) job title and team details.
- Enquiry and booking data: the message you send us, your preferred service (individual, corporate, coaching, assessment), team size and preferred dates.
- Assessment data: if you take the iEQ9 assessment, your questionnaire responses and resulting profile data, processed by our assessment partner Integrative Enneagram Solutions (trading as Integrative9).
- Coaching session notes: brief, confidential notes Clair keeps for continuity of your coaching relationship. These are stored securely and not shared.
- Payment data: we use a third-party payment processor — we never see or store your full card details.
- Website usage data: if you accept analytics cookies, anonymised data about pages visited, traffic source and device type. See our Cookie policy.
- Marketing preferences: whether you've opted in to hear from us, and which channels.
3. How we use your personal data
We use personal data for the following purposes:
- To respond to your enquiry and discuss whether our services are a fit (legal basis: legitimate interest).
- To deliver our coaching, assessment and workshop services once you become a client (legal basis: contract).
- To process and administer payments (legal basis: contract).
- To send you essential service messages — booking confirmations, debrief scheduling, important account updates (legal basis: contract).
- To send you marketing communications if you have opted in (legal basis: consent).
- To improve our website and services using anonymised analytics (legal basis: consent, via the cookie banner).
- To meet legal and regulatory obligations — for example, tax records or responding to lawful requests (legal basis: legal obligation).
4. Who we share your data with
We do not sell your personal data. We share it only where necessary to deliver our services, meet legal obligations, or with your consent. Our recipients include:
- Integrative Enneagram Solutions (trading as Integrative9): our assessment platform, used to deliver the iEQ9 questionnaire and generate your report. Primary contact address: Walton-on-Thames, KT12 2TX, England. As an international platform they may process data in jurisdictions outside the UK; see International transfers below.
- Email: Google Workspace, for our @integritystudioco.com email.
- Scheduling and bookings: Fresha, used to schedule discovery calls and sessions.
- Payment processor: Fresha (which uses Stripe under the hood). We never see or store your full card details.
- Hosting and analytics: Vercel (website hosting) and Google Analytics 4 (only if you accept analytics cookies).
- Professional advisors: our accountants, legal advisors or auditors where this is necessary for regulatory compliance.
- Authorities: if required by law, court order or to protect our legal rights.
5. International transfers
Some of our service providers (including Integrative9, Google services and Vercel) operate internationally and may process data outside the UK. Where this happens, we rely on appropriate safeguards — such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or an adequacy regulation — to ensure your data is protected to UK standards.
6. How long we keep your data
- Enquiry data: up to 12 months from your last contact, then deleted unless you become a client.
- Client records (including assessment data and session notes): for the duration of our coaching relationship plus 7 years thereafter, to meet our professional and tax record-keeping obligations.
- Financial records: 7 years from the end of the relevant tax year, as required by HMRC.
- Marketing preferences: until you unsubscribe; we keep a record of your unsubscribe so we can honour it.
- Website analytics: see our Cookie policy for retention by cookie.
7. How we keep your data secure
We take security seriously. Our practices include encrypted-at-rest cloud storage, strong access controls, multi-factor authentication on accounts that handle personal data, regular review of who has access, and secure deletion when data is no longer needed. We hold BSI ISO 27001 standards alignment as part of our broader information-security commitment.
No method of transmission over the internet or method of electronic storage is 100% secure — but we apply industry-standard safeguards and review them regularly.
8. Direct marketing
We only send marketing communications to people who have opted in to receive them. You can opt out at any time:
- Email: click the Unsubscribe link at the bottom of any marketing email.
- SMS: reply STOP to any marketing text.
- By email: hello@integritystudioco.com with subject line "Unsubscribe".
Opting out of marketing won't stop essential service messages such as booking confirmations.
9. Your rights under UK GDPR
You have the right to:
- Access the personal data we hold about you.
- Rectify inaccurate or incomplete data.
- Erase your data, where there is no compelling reason for us to keep it.
- Restrict our processing of your data in certain circumstances.
- Portability — receive your data in a structured, machine-readable format.
- Object to processing based on our legitimate interests, and to direct marketing.
- Withdraw consent at any time where we rely on consent (this won't affect any processing already carried out).
- Lodge a complaint with the Information Commissioner's Office (see below).
To exercise any of these rights, email hello@integritystudioco.com. We aim to respond within one month. We may ask you to verify your identity before we release information.
If you are unhappy with how we have handled your data, please first see our Data protection complaint policy. You can also complain to the ICO at ico.org.uk or 0303 123 1113.
10. Cookies
We use a small number of cookies, only with your consent for anything beyond essentials. Our Cookie policy explains in detail.
11. Children
Our services and this website are intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18.
12. Changes to this policy
We may update this policy from time to time — for example, to reflect new services, new processors, or changes in the law. The "Last updated" date at the top of this page will reflect the most recent change. Where changes are material, we will let you know directly (for example, via email if you are a current client).
13. Business transfers
If we ever sell, transfer or merge any part of our business, your personal data may be transferred to the new owner so they can continue to provide services to you. Where this happens, you will be told and the new owner will be required to honour the commitments in this policy.
14. Contact
Privacy questions, rights requests or complaints — email hello@integritystudioco.com, or write to Integrity Studio Co. Ltd, 124 City Road, London, EC1V 2NX, United Kingdom — marked FAO Data Protection.