Your privacy matters. This policy explains what personal information CEIBA collects when you use this website, why we collect it, and the rights you have over it under UK data protection law.
01Who we are
This website is operated by CEIBA, the trading name of Geraldine Spencer, the transformational coaching practice founded by Gerry Spencer. In this policy, “CEIBA”, “we”, “us” and “our” refer to that practice, which is the data controller responsible for your personal information.
- Contact for data matters: gerry@ceibamethod.co.uk
- Postal address: 1 Brame Hall Farm, Harrogate, HG3 1SB
02The information we collect
We only collect the information we need to respond to you and to run this website. Depending on how you use the site, that may include:
Information you give us
- Discovery call and enquiry form: your name and email address, and, if you choose to provide them, your phone number and any message describing what you are navigating.
- Live chat: the name and email address you enter before starting a chat, and the content of the messages you send and receive.
- Direct contact: anything you include if you email us or contact us by other means.
Information collected automatically
- Technical and log data: our hosting provider records standard server information such as your IP address, browser type, and the pages you request. This is used to deliver the site securely and reliably.
- A chat identifier: when you start a live chat, a small anonymous token is stored in your browser so your conversation can continue across page loads. It does not identify you on its own.
We do not use advertising trackers, and we do not buy or sell personal data.
03How we use it and our lawful bases
Under UK GDPR we must have a lawful basis for using your personal information. Our uses and bases are:
- To respond to your enquiry or discovery call request and arrange a call. Basis: consent, and taking steps at your request before entering into a contract.
- To provide live chat and reply to your messages. Basis: consent and our legitimate interests in helping people who contact us.
- To provide our coaching services where you go on to work with us. Basis: performance of a contract with you.
- To keep the website secure and working and to prevent misuse. Basis: our legitimate interests in a safe, functioning service.
- To meet legal or regulatory obligations where these apply. Basis: legal obligation.
Where we rely on consent, you can withdraw it at any time by contacting us. Withdrawing consent does not affect anything we did before you withdrew it.
04Cookies and local storage
This site is deliberately light on cookies. We do not use analytics, advertising, or tracking cookies.
- Strictly necessary items: the live chat feature stores a small token in your browser so your conversation works. If the site owner logs in to the private admin area, a session cookie is used to keep them signed in. Our booking, enquiry and chat forms use Cloudflare Turnstile, which may set a cookie to confirm you are not a bot before your submission is accepted. These are essential and do not require consent.
Because we set only strictly necessary storage for visitors, you will not see a cookie consent banner. You can clear this storage at any time through your browser settings.
06International transfers
Some of the providers above are based outside the UK, including in the United States. Where your information is transferred abroad, we rely on appropriate safeguards recognised under UK data protection law, such as the UK International Data Transfer Agreement or the UK extension to the EU Standard Contractual Clauses, so your information keeps a similar level of protection.
07How long we keep it
We keep personal information only for as long as we need it:
- Enquiries and discovery call requests: for as long as we are in contact with you and for up to 12 months after our last contact, unless you become a client.
- Live chat transcripts: for up to 12 months, then deleted.
- Client records: for the duration of our work together and for any period required by our professional, tax, or legal obligations.
When information is no longer needed, we delete it or make it anonymous.
08Your rights
Under UK GDPR you have the right to:
- ask for a copy of the personal information we hold about you;
- ask us to correct information that is wrong or incomplete;
- ask us to delete your information in certain circumstances;
- ask us to restrict or object to how we use it;
- ask us to transfer certain information to you or another provider;
- withdraw consent at any time where we rely on it.
To exercise any of these, email gerry@ceibamethod.co.uk. We will respond within one month. There is normally no charge.
09How we keep it secure
The site is served over an encrypted connection, and enquiry and chat records are held in a protected database accessible only through a private, password protected admin area. While no online service can be guaranteed completely secure, we take reasonable steps to protect your information against loss, misuse, and unauthorised access.
10Children’s privacy
This website and our services are intended for adults. We do not knowingly collect information from children under 16. If you believe a child has provided us with personal information, please contact us and we will delete it.
11External links and content
Our site may link to other websites and displays images hosted by third parties. We are not responsible for the privacy practices of those other sites. We encourage you to read their privacy notices.
12Changes to this policy
We may update this policy from time to time. When we do, we will change the date shown at the top of the page. Please check back occasionally so you are aware of any updates.
13How to contact us
Questions or requests
Email gerry@ceibamethod.co.uk for anything relating to your privacy or the information we hold.
You also have the right to complain to the Information Commissioner’s Office (ICO), the UK data protection regulator, at ico.org.uk/make-a-complaint or on 0303 123 1113. We would welcome the chance to resolve your concern first, so please do consider contacting us before you approach the ICO.