Personal data we collect
Identity/contact data: name, email, phone.
Payment and billing data (for paid services).
Communications and client records (messages, session notes).
Usage and technical data: IP address, device/browser, cookies, analytics data.
Marketing preferences.
Purpose & legal basis for processing
Provide coaching services, manage client relationships, deliver purchases — lawful basis: performance of a contract and/or legitimate interests.
Send marketing and newsletters — lawful basis: consent (you may withdraw consent anytime).
Improve website and analytics — lawful basis: legitimate interests or consent for marketing/advertising cookies.
Comply with legal obligations (tax, accounting) — lawful basis: legal obligation.
Third parties and transfers
We may share personal data with:
Payment processors (Stripe, PayPal, etc.)
Hosting and email providers (e.g., web host, email platform, CRM, LMS)
Professional advisors (accountants, lawyers) when necessary These providers act as processors and are contractually bound to protect your data. Transfers outside the EEA will only occur where adequate safeguards exist (EU adequacy decision, Standard Contractual Clauses, or explicit consent).
Cookies and tracking
We use cookies for essential functionality, analytics, and marketing. On your first visit we will request consent for non-essential cookies. You can manage cookie preferences via our cookie banner or browser settings.
Data retention
Client/service records: retained for the duration of the business relationship and for legal/tax retention periods (typically up to 6 years in Spain for accounting records).
Marketing data: retained until consent is withdrawn.
Analytics/technical logs: retained for a limited period (e.g., 12–24 months) unless anonymized.
Your rights
Under GDPR you have the right to:
Access your personal data
Rectify inaccurate data
Erase (right to be forgotten) in certain circumstances
Restrict processing
Object to processing (including direct marketing)
Data portability (where applicable)
Withdraw consent at any time To exercise your rights, contact: [contact email/address]. If unresolved, you can lodge a complaint with the Spanish data protection authority (AEPD — https://www.aepd.es/).
Security
We implement appropriate technical and organizational measures to protect your data (encryption, access controls, regular backups). However, no internet transmission is completely secure.
Minors
Our services are intended for adults. We do not knowingly collect personal data from minors under 16 without parental consent. If you believe we have collected a child’s data, contact us to request deletion.
Changes to this policy
We may update this policy; we will post the revised policy on the website with an updated effective date.
Contact / Controller details

© David J Bush 2026 | All Rights Reserved.