Privacy Policy

This policy explains what personal information HME Online Limited collects, why we use it, who may receive it, how long we keep it and the rights you have. It applies to the Her Midlife Empowerment website, bookings, coaching services, emails, resources and related communications.

Who is responsible for your information

HME Online Limited, trading as Her Midlife Empowerment, is the data controller for the personal information covered by this policy. HME Online Limited is registered in England and Wales under company number 17296830. Our registered office is Regus C/O Ginger Bucks Ltd, Central Boulevard, Solihull, West Midlands, England, B90 8AG.

HME Online Limited is registered with the Information Commissioner’s Office. Our registration reference is ZC205963.

For privacy questions or requests, email [email protected].

The information we collect

We collect only the information reasonably needed to operate the website, respond to you and provide the services you choose to use.

Contact and identity information. This may include your name, email address, telephone number, country, town or general location, time zone and preferred way to meet.

Booking and service information. This may include the service selected, appointment date and time, answers provided in booking or preparation forms, rescheduling and cancellation records, attendance information, communications and information needed to provide the service.

Coaching information. If you become a client, we may keep relevant preparation answers, working notes, session records, written summaries, agreed actions, feedback and communications connected with the coaching relationship.

Wellbeing and other sensitive information. You may choose to tell us information about your physical or mental health, wellbeing, disability, relationships or other personal circumstances. Some of this may be special category data under data protection law. Please provide only information you consider relevant. Where explicit consent or another additional legal condition is required, we will identify and record it separately.

Quiz and resource information. When you complete the Midlife ARC™ quiz, request a free resource or use another interactive feature, we may collect your answers, result, first name, email address and choices about follow-up communications.

Payment and transaction information. We receive information such as the service purchased, price, payment status, date, refunds and an invoice or transaction reference. Complete card or payment-account details are collected and processed by the payment provider, not stored by HME.

Marketing preferences. We record whether you asked to receive the Weekly Letter, resource follow-up emails or other optional communications, together with unsubscribe and consent records.

Website and device information. Depending on your cookie choices, this may include your IP address, browser, device, pages viewed, approximate location, referral source and information about how the website performs and is used.

How we obtain information

Most information comes directly from you when you use the website, complete a form, book or pay for a service, communicate with us or take part in coaching.

We may also receive limited information from a person or organisation paying for a gift, an employer or sponsor funding support, a referral source you have authorised, our booking and payment providers, or technical services used to operate the website.

If someone buys a service for you, we may receive your name and contact details from the purchaser. We will provide privacy information to you when we contact you and will not require you to participate.

Why we use information and our legal bases

Data protection law requires us to have a lawful basis for each use of personal information. Depending on the activity, we rely on the following bases.

Contract and steps before a contract. We use information to respond to a booking request, administer appointments, take payment, provide coaching, deliver purchased services, manage cancellations and refunds, and communicate about the service.

Consent. We use consent for optional marketing emails and where another use specifically requires it. You can withdraw consent at any time. Withdrawing consent does not affect processing that was lawful before withdrawal.

Legitimate interests. We may use information where reasonably necessary to run and improve the business, maintain appropriate records, understand service use, prevent misuse, protect systems, respond to concerns and establish or defend legal claims. We consider the effect on your rights before relying on this basis.

Legal obligation. We use and retain information where required for tax, accounting, company, consumer-protection, safeguarding or other legal responsibilities.

Special category information. Where we process special category information, we also rely on an appropriate additional condition, usually your explicit consent where the information is provided voluntarily for coaching. In limited circumstances, another condition may apply, including the establishment or defence of legal claims or the protection of vital interests where the law permits it.

When information is required

Some information is needed to make or administer a booking and provide the service, including your name, contact details and booking information. If you do not provide it, we may be unable to accept or deliver the service.

Preparation questions and coaching discussions may contain optional fields. You do not have to disclose anything you do not wish to discuss, although limited information may affect how fully we can tailor the service.

Who may receive your information

We do not sell or rent personal information and do not share it with another business for that business’s own marketing.

We may use carefully selected providers to help operate the business, including:

• ExpertSpace and its underlying services for website hosting, forms, bookings, client administration and email delivery;
• the payment providers displayed during checkout for payments, refunds and fraud prevention;
• Google services for email, documents, calendar invitations and Google Meet;
• WhatsApp where you choose a WhatsApp telephone session or communicate through that service;
• website security, infrastructure, analytics and cookie-management providers;
• accountants, insurers, professional advisers and technical support providers where reasonably necessary; and
• regulators, courts, law-enforcement bodies or other authorities where disclosure is required or permitted by law.

Providers may receive only the information needed for their role and must handle it under their own legal and contractual responsibilities.

Employer-funded and sponsored services

Where an employer, business or another organisation pays for support, the person receiving coaching remains the client unless we clearly agree otherwise. The payer may receive necessary administrative information such as the service purchased, invoices and agreed attendance information.

We do not share the content of coaching conversations, session notes or a written review summary with the payer without the client’s clear permission, unless disclosure is required by law or another confidentiality limit applies.

International clients and international processing

We may provide virtual services to clients outside the UK. Sending information directly to an individual client in another country is not treated in the same way as transferring information to an overseas organisation.

Some technology providers or their supporting companies may process information outside the UK. Where UK data protection law treats this as a restricted international transfer, we use an applicable safeguard, such as UK adequacy regulations, an approved contractual safeguard or another lawful transfer mechanism.

How long we keep information

We do not keep personal information indefinitely. The period depends on why it was collected and any legal, insurance, accounting or dispute-related requirement.

• General enquiries and records of free conversations are normally retained for up to two years after the last meaningful contact.
• Client, booking and coaching records are normally retained for up to seven years after the coaching relationship ends, unless a longer or shorter period is justified.
• Transaction, invoice and accounting records are normally retained for six years after the end of the relevant financial year.
• Marketing information is kept until you unsubscribe or we no longer need it. We may keep a minimal suppression record so that we respect an unsubscribe request.
• Recordings and transcripts created at your request are deleted from our systems after they have been shared with you, unless another retention period is expressly agreed.
• Cookie choices are normally remembered for up to 180 days.

We may retain limited information for longer where reasonably needed to respond to a complaint, establish or defend a legal claim, comply with law or preserve evidence of consent and privacy preferences.

Recordings and transcripts

Sessions are not recorded or transcribed unless you request or expressly agree to this in advance. If a recording or transcript is created, we will explain its purpose, how it will be shared and how long it will be retained.

Email and marketing choices

Requesting a resource, completing the quiz or booking a service does not automatically subscribe you to unrelated marketing.

We send the Weekly Letter and other optional marketing only where we have an appropriate legal basis, normally your consent. You can unsubscribe using the link in any marketing email or by contacting [email protected]. Service messages about a booking or active client relationship are not marketing and may still be sent where necessary.

Cookies and similar technologies

This website uses cookies and similar technologies. Essential technologies support security, website delivery, forms, bookings and your cookie choices. They may operate without consent where the law permits.

Optional functional, analytics, performance or advertising technologies are controlled through the cookie banner. You can accept optional technologies, continue with essential technologies only or customise your choices.

The Instagram feed on the homepage is provided through SnapWidget. Third-party content may use optional technologies for functionality, measurement or advertising and should remain blocked unless the relevant cookie choice permits it.

ExpertSpace and its underlying services, together with infrastructure providers such as Cloudflare, help deliver, secure and monitor the website. Technologies that are strictly necessary for security or delivery remain active. Optional measurement technologies are subject to the choices available through the cookie banner.

Your cookie choice is normally remembered for up to 180 days. You can change it sooner through the cookie settings where available or by clearing the cookies and website data for hme.coach in your browser and reloading the site.

Security

We use reasonable technical and organisational measures intended to protect personal information against unauthorised access, loss, misuse or alteration. No website, email service or internet transmission can be guaranteed completely secure.

Please do not send highly sensitive information through ordinary email unless it is necessary and you are comfortable doing so. Contact us if you would like to discuss an appropriate way to share information.

Your data protection rights

Depending on the circumstances, you may have the right to:

• ask for access to the personal information we hold about you;
• ask us to correct inaccurate or incomplete information;
• ask us to delete information;
• ask us to restrict how information is used;
• object to processing based on legitimate interests or direct marketing;
• receive certain information in a portable format;
• withdraw consent where processing relies on consent; and
• complain to the Information Commissioner’s Office.

These rights are not absolute and may depend on why the information is held. To make a request, email [email protected]. We may need to confirm your identity before acting. We will respond without undue delay and normally within one month.

How to complain

Please contact us first if you have a concern about how your information has been handled. Email [email protected] and we will investigate.

You also have the right to complain to the Information Commissioner’s Office:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113
Website: ico.org.uk/make-a-complaint

Children

Our coaching services are intended for adults aged 18 or over. We do not knowingly offer coaching to children or intentionally collect children’s information through the booking process.

Automated decision-making

We do not use personal information to make solely automated decisions that produce legal or similarly significant effects. Quiz results are generated from the answers selected, but they do not determine whether you can access a legal right or essential service.

Changes to this policy

We may update this policy when the website, services, providers or legal requirements change. The date at the top shows when it was last updated. Material changes will be brought to your attention where appropriate.

Questions

If anything here is unclear, email [email protected].

See also our Website Terms of Use and Booking Terms.