This policy together with our website terms and conditions describes how Penny de Valk collects, stores and uses personal data about you. Please read it carefully in conjunction with our website terms and conditions, as well as any updates that may be issued from time to time.

Data Controller

For the purposes of data privacy laws the data controller is Penny De Valk Growth Advisor Limited, whose registered office is at Suite 2, Westley Chambers, Queens Road, Aldershot, Hampshire GU11 3 JD. This is the entity that is responsible for deciding how we collect, use and store personal data and which has responsibility for making sure that we do this in full compliance with data protection law. In the rest of this document “we/us/our” refers to Penny De Valk Growth Advisor Limited.

The data we collect

Most of the personal data that we collect and hold about you will be provided directly by you. This may include details from any forms that you fill in on our website including name and contact details, bookings for any of our services and the issues you are seeking to address through coaching, as well as information that you provide to us either by email, telephone, Skype or other means of communication during the course of discussions about the services we may be able to offer you, as well as during dialogue (whether oral or written) during the course of our provision of coaching, mentoring or other services.

In addition to personal data that you give to us we may also collect:

  • data that you have shared publicly, such as LinkedIn
  • data that has been supplied to us by your employer if they are sponsoring your use of our services, which will usually be information about the areas in which they perceive you may benefit from coaching
  • any third party whom you directly authorise us to speak to in support of our provision of services to you, for example you may ask a colleague who may give feedback on your management or communication style.

Transparency is important to a successful coaching/mentoring relationship and when we collect information about you from your employer or from any other third party that you authorise us to speak to then it will be on the understanding that we will share this information with you.

With your agreement we may record coaching and mentoring sessions that we have with you. If we do make a recording then this will be solely for your personal use: we will either send it to you and then delete any copy on our systems, or if you say you do not want a copy of the recording we will delete it straight away.

We will also hold financial records about the payments that you have made to us in respect of our services, however we use either Stripe or Paypal to collect payments, which means that we will not hold any records of the payment method (such as credit or debit card numbers). You can find information about how Stripe and Paypal use your personal data at Stripe and Paypal.

The purposes for which we use your personal data

We use any personal data that we collect about you for the purpose of discussions prior to our entering into a contract to deliver services; for the delivery of any services you buy; and for keeping any records that we are required to for the purposes of complying with our legal obligations, for example the maintenance of proper financial records.

If you specifically consent to receive marketing messages from us then we may from time to time send you messages about other services that we offer or that we think may be of interest to you. We will not share your personal data with anyone for the purposes of third party marketing campaigns. If you have consented to receive marketing messages from us but then change your mind you can ask us to remove your contact details from the marketing list at any time by either unsubscribing to a message received or emailing us on using “unsubscribe” as the email title.

We use third parties to provide us with certain services such as IT hosting, video conferencing financial and legal advice. We may share your personal data with them if it is necessary for them to provide us with services but always on the basis that they are under a strict obligation to keep any personal data confidential and not to use it for any purpose other than one we have requested. We undertake appropriate diligence on our third party providers to ensure that they will hold your personal data in compliance with our obligations to you.

Except as set out above we will not share your data with anyone without your consent.

How we store your personal data

We take all reasonable steps to ensure that your personal data is held securely. All personal data that we hold about you is stored on secure servers in the UK. Whilst providing services to you Penny de Valk may take handwritten notes. These will be scanned onto our system and the originals will be securely disposed of.

Please note that we use the internet including email and Skype to provide services to you. Although all reasonable steps are taken to protect your privacy we cannot guarantee the security of any communication that takes place over the internet.

Transfers and processing of your data outside the EEA

The services we offer are provided by telephone, email and other virtual means. This offers the advantage that you and your coach/mentor can have the flexibility to receive or deliver our services from anywhere in the world. It also means that although the servers on which we hold all personal data are in [the UK], we may transfer or process your personal data to any country in which the coach is located, including countries which are not considered by the EU Commission to have adequate personal data protections. We will take all reasonable measures including but not limited to encryption and password protection to ensure that the only party who can access your personal data from outside the EEA is Penny de Valk. We will not share your data with any third party data processor who is based outside the EEA/ we will seek undertakings from any third party processing data on our behalf that any data processing which is performed outside the EEA is done under standards that are at least equivalent to the protections offered to you under EU and UK law.

How long we keep your personal data

We only keep your data for as long as it is needed. Depending on the reasons we hold it this means that your personal data may be held for different lengths of time, as follows:

  • any recordings that we make of conversations with you are deleted immediately after either you say you do not want a copy or we have sent you a copy.
  • records of discussions with a view to you using our services are deleted after 6 months if you have not booked to use a service by that time.
  • records of all information processed in relation to coaching and mentoring services are deleted 12 months after the conclusion of the service.
  • if you have opted in to receive marketing information from us we will keep your contact details until you tell us that you no longer want to be contacted by us.
  • we will keep financial information about the fees that you have paid to us for up to 6 years after the end of the tax year in which payment was made, for the purposes of fulfilling our statutory tax and financial reporting obligations.

Your data privacy rights

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.
  • Make a complaint about our use or handling of your personal data at any time to the Information Commissioner’s Office (ICO) , which is the UK supervisory authority for data protection issues.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Penny de Valk in writing.


If you have any questions or want to contact Us with regard to any data privacy details please get in touch with Our representative Penny De Valk on