Privacy Policy

For Ryan Hogarty Ltd (Trading as Ryan Hogarty Business Coaching)

Last Updated: May 2026

1.Introduction & Who We Are

Welcome to the Privacy Policy for Ryan Hogarty Ltd, trading as Ryan Hogarty Business Coaching. We respect your privacy and are committed to protecting your personal data.

This Privacy Policy informs you about how we look after your personal data when you visit our website, engage our coaching services, or otherwise interact with us. It also tells you about your privacy rights and how the law protects you under the UK General Data Protection Regulation UK GDPR and the Data Protection Act 2018.

2. Contact Details

Ryan Hogarty Ltd is the data controller responsible for your personal data. If you have any questions about this privacy policy or our data practices, please contact us:

Full Name of Legal Entity: Ryan Hogarty Ltd

Email Address: ryan@ryanhogarty.com

Postal Address: 21 Holtham Avenue Churchdown Gloucestershire GL32AR


3. The Data We Collect About You

Personal data means any information about an individual from which that person can be identified. We may collect, use, store, and transfer different kinds of personal data about you, grouped as follows:

Identity Data: First name, last name, username or similar identifier, and job title.

Contact Data:Billing address, email address, and telephone numbers.

Financial Data: Bank account and payment card details (processed securely via third-party payment gateways).

Transaction Data: Details about payments to and from you and other details of services you have purchased from us.

Coaching & Interaction Data: Notes from coaching sessions, goals, business metrics, assessment results, and communication preferences.

Technical & Usage Data:  IP address, browser type, and information about how you use our website or scheduling tools.


4. How Your Data Is Collected

We use different methods to collect data from and about you, including:

Direct Interactions: You may give us your Identity, Contact, and Financial Data by filling in forms, booking a discovery call, or by corresponding with us by post, phone, email, or otherwise.

Coaching Sessions: Information you share during face-to-face, video, or audio coaching sessions.

Third Parties or Publicly Available Sources: We may receive technical data from analytics providers (like Google Analytics) or identity/contact data from public platforms like LinkedIn.



5. How We Use Your Data & Our Third-Party Processors

We only use your personal data when the law allows us to. Most commonly, we use your data to perform the contract we are about to enter into or have entered into with you, or where it is necessary for our legitimate business interests.

To provide high-quality business coaching, we rely on specific digital tools. Below is how your data is processed within these platforms:

5.1. Delenta Coaching App

Purpose:We use Delenta as our central client management and coaching platform.

Data Processed:Your identity, contact details, coaching contracts, coaching notes, invoices, session scheduling, and coaching logs/milestones.

UK GDPR Compliance: Delenta acts as a data processor on our behalf. Data is stored securely, and their platform features strict access controls to protect your sensitive business information.

5.2. Google Business Suite (Google Workspace)

Purpose: We use Google Workspace for daily business communications, email management, document creation, calendar scheduling, and secure video conferencing (Google Meet).

Data Processed:Emails, shared documents, meeting recordings (where explicitly agreed upon), and calendar invites.

UK GDPR Compliance: Google operates under strict Data Processing Addendums (DPAs) incorporating Standard Contractual Clauses (SCCs) to protect data transferred outside the UK.

5.3 Gemini AI

Purpose: To maximise the value of your coaching, we use Gemini AI to assist with summarising anonymised session insights, organising action items, structuring business strategies, and drafting communication templates.

Data Processed: Text-based notes, action lists, or high-level summaries generated during or after our coaching sessions.

UK GDPR Compliance:  When using Gemini AI, we strictly limit the input of highly sensitive personal identifiers. Furthermore, we configure our AI tools to ensure data inputs are kept private and are not utilised to train public machine learning models.

5.4 MailerLite

  • Purpose: We use MailerLite to host our web pages/landing pages, manage our email subscriber lists, and distribute marketing campaigns or newsletters.
  • Data Processed: Name, email address, marketing preferences, signup timestamps, and email engagement analytics (opens/clicks).
  • UK GDPR Compliance: MailerLite acts as a data processor. For UK and European users, data is stored securely on servers located inside the European Union (primarily Germany and the Netherlands), maintaining data protection parity via the UK-EU adequacy regulations.

5.5 Xero Accounting Software

  • Purpose: We use Xero to generate professional invoices, log financial transactions, track payment completions, and manage our business tax reporting.
  • Data Processed: Client name, business name, billing address, email address, invoice breakdowns, and transaction history.
  • UK GDPR Compliance: Xero operates as a secure data processor. While data is stored securely via cloud architecture (such as Amazon Web Services) which may involve cross-border transfers, Xero utilizes a robust Data Processing Agreement (DPA) incorporating Standard Contractual Clauses (SCCs) to ensure equivalent UK GDPR protections.



6 . Lawful Bases for Processing

We process your data under the following legal frameworks:

Performance of a Contract: To deliver the business coaching services you have hired us to provide.

Legitimate Interests: For the efficient administration and marketing of our business, provided your fundamental rights do not override those interests.

Consent: Where you have explicitly opted in to receive marketing materials or newsletter updates (which you can withdraw at any time).


7. International Data Transfers

Some of our third-party service providers (such as Google and Delenta) are based outside the United Kingdom, meaning their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We transfer data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government.

We use specific Standard Contractual Clauses (SCCs) or the International Data Transfer Addendum (IDTA) approved for use in the UK, which give personal data the same protection it has in the UK.

---

8. Data Security & Retention

Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way. Access to your personal data is restricted to Ryan Hogarty Ltd and the authorized software platforms mentioned above.

Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. By UK law, we must keep basic information about our clients (including Contact, Identity, Financial, and Transaction Data) for 6 (Six) years after they cease being clients for tax purposes.

---

9. Your Legal Rights

Under the UK GDPR, you have rights in relation to your personal data, including the right to:

Request access to your personal data (commonly known as a "data subject access request").

Request correction of the personal data that we hold about you.

Request erasure of your personal data where there is no good reason for us continuing to process it.

Object to processing of your personal data where we are relying on a legitimate interest.

Request restriction of processing of your personal data.

Request the transfer of your personal data to you or to a third party.

Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of these rights, please contact us at the email address provided in Section 2.


9. How to Complain

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.