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1. Introduction

Welcome to Overcome.org.uk (“we,” “us,” “our”). Your privacy is important to us, and we are committed to protecting your personal data. This policy outlines how we collect, use, and protect your personal data when you use our mental health coaching services.

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2. Information We Collect at Sign-Up

We collect:

• Personal Information: Name, email address, and any information you voluntarily provide.
  Marketing Data: UTMs (Urchin Tracking Modules) to assess marketing performance.
  Technical and Usage Data: Anonymous data via third-party services (e.g. Google Analytics, Wix) such as browser type, device info, and general usage patterns.

 

3. Information Collected During the Coaching Programme

If you engage with our coaching services, we may collect:

• Communication Data: Email read receipts for user wellbeing and safety.

• Session Notes: Summaries written by your coach to keep track of your progress, and for management to review your case if we are concerned about your safety.

• Surveys: Routine feedback and wellbeing questionnaires, and testimonials upon completion.

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4. How We Use Your Information

We use your data to:

• To provide, manage, personalise and evaluate our coaching services.

• To analyse and improve our marketing efforts using UTMs.

• To monitor safety and engagement through email read receipts and session data.

• To communicate essential coaching communication and, with consent, marketing messages.
  To comply with legal obligations.

 

5. Legal Basis for Processing

We process data based on:

• Contract: To provide services.

• Legitimate Interest: To improve services and marketing.

• Legal Obligation: To comply with the law.

• Consent: For coaching communication (e.g. coach emails you to book your first session) and marketing.

 

6. Data Sharing and Disclosure

We do not sell your data. We may share it with:

• Operational service providers (e.g., email delivery, analytics).

• Authorities where required by law to ensure user safety or comply with regulations.

• Marketing platforms anonymously to understand the demographics of those visiting our websites or campaigns.

• Partnering organisations, if you signed up via one of our partnerships. We will share anonymised summaries of client retention and outcomes to evaluate the effectiveness of the partnerships.

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7. Data Retention
We retain your data only as long as necessary for the purposes outlined or as required by law.

 

8. Data Security
We implement robust security measures to protect your data:

• GDPR and HIPAA-compliant forms (rated A by UpGuard, July 2025).

• Password-protected, two-factor authenticated database (also rated A by UpGuard).

• Access is limited to your coach, their line manager, and senior management.

 

9. Your Rights

You have the right to:

• Access, amend or delete your data.

• Restrict or object to processing in certain cases.

• Withdraw consent at any time.

• Lodge a complaint with your local data authority.

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All clients also have the right to:

• Stop using our service at any time.

• Choose what they disclose.

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10. Cookies and Tracking
We use cookies and similar technologies for analytics and marketing. You can control these through your browser settings.

11. Third-Party Links
Our website may contain links to third-party websites. During the coaching programme, coaches may signpost clients to third-party websites for additional resources and services. We are not responsible for their privacy practices.

 

12. Artificial Intelligence (AI)

Coaches are never authorised to use artificial intelligence tools during sessions without your explicit consent. Coaches and other Overcome staff are never authorised to enter any personally identifiable information into any AI model under any circumstances. If you have any specific requests around AI, email clients@overcome.org.uk before signing up. If you’ve already signed up, please email your coach and clients@overcome.org.uk to notify us.

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13. Updates to This Policy
We may update this policy periodically. The latest version will always be available on our website.

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14. Contact Us

For any questions or requests regarding this Privacy Policy, contact us at enquiries@overcome.org.uk