Privacy Policy

Effective Date: 15 January 2025
Last Updated: 21 May 2026

Alan Newton and/or NewtonSquared Ltd (referred to as "we," "us," or "our") is committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy explains how we collect, use, and protect your information when you engage with our coaching services.

1. Information We Collect.

We may collect and process the following personal data about you:

  • Personal Information: Name, email address, phone number, job title, employer details, and any other information you provide when contacting us or signing up for our services.

  • Session Notes: Insights and reflections shared during coaching sessions.

  • Billing Information: Address, payment details, and transaction records.

  • Website Data: IP address, browser type, and cookies (if applicable to website usage).

We only collect information necessary for providing coaching services or required by law.

2. How We Use Your Information.

We use your personal data for the following purposes:

  • To provide and manage our coaching services.

  • To communicate with you, including responding to inquiries and scheduling sessions.

  • To maintain records for contractual and legal obligations.

  • To process payments and manage invoices.

  • To send relevant information about our services (with your consent, where required).

3. Legal Basis for Processing.

We process your personal data under the following legal bases:

  • Contractual Obligation: To fulfil our coaching agreement with you.

  • Legitimate Interests: For the purpose of managing and improving our services.

  • Consent: For marketing or other non-essential communications, where you have explicitly provided consent.

4. How We Share Your Data.

We do not sell or share your personal data with third parties for marketing purposes. However, we may share your data with the following entities:

  • Service providers assisting with payment processing, scheduling, or email communication.

  • Legal or regulatory authorities, if required by law.

All third parties are required to protect your data and use it only for the intended purposes.

5. Data Retention.

We will retain your personal data only for as long as necessary for:

  • The duration of our coaching relationship.

  • Legal, tax, or accounting purposes (typically 6 years for financial records).

  • Resolving disputes or enforcing our agreements.

After this period, we will securely delete or anonymise your data.

6. AI Use and Transparency.

We may use artificial intelligence and AI-enabled software tools to support certain internal and client service activities, including research support, drafting, note-taking, transcription, summarisation, document analysis, organisation of information, writing assistance, communication, and operational efficiency. These tools are used to support human work and judgment, not to replace it.

Where appropriate to the engagement, we may process personal data and confidential business information using approved cloud, communication, transcription, note-taking, document management, writing-assistance, and AI-enabled productivity tools. This may include meeting transcripts, notes, emails, documents, presentations, contact information, and other materials shared by or relating to clients, prospects, counterparties, or stakeholders.

We seek to use private, restricted, or business-configured environments where available, and to apply proportionate safeguards including data minimisation, access controls, and human review of outputs. Where such controls are available and enabled, we do not intentionally permit client data submitted through these environments to be used to train third-party AI models.

AI-assisted outputs are reviewed by a human before they are relied upon or used in final advice, recommendations, communications, or deliverables. We do not use solely automated decision-making, including profiling, that produces legal effects or similarly significant effects on individuals as part of its standard services.

We may also use AI-assisted tools to support internal business-development activity, including screening organisations or individuals for potential outreach and sense-checking information following chemistry or discovery calls. These activities are used to inform human judgment and are not used as the sole basis for significant decisions about individuals.

Where meetings are recorded, transcribed, or summarised using AI-enabled tools, participants will be notified at the time of the meeting through the relevant platform or meeting workflow and may request that recording or transcription be turned off where appropriate.

If a client wishes to discuss additional restrictions on the use of AI-enabled tools for particularly sensitive, confidential, regulated, or legally privileged materials, they may raise this with NewtonSquared before or during the engagement so that an appropriate working approach can be considered where feasible.

7. Your Data Rights.

Under the UK GDPR, you have the following rights regarding your personal data:

  • Access: Request access to your data and obtain a copy.

  • Correction: Request corrections to any inaccuracies in your data.

  • Deletion: Request deletion of your data, subject to legal or contractual obligations.

  • Restriction: Request a halt to specific processing activities.

  • Data Portability: Request transfer of your data to another service provider.

  • Objection: Object to processing based on legitimate interests.

  • Withdraw Consent: Withdraw consent for non-essential processing (e.g., marketing).

To exercise your rights, please contact us using the details in Section 10.

8. Data Security.

We implement appropriate technical and organisational measures to safeguard your data, including encryption, access control, and secure storage systems. However, no system is completely secure, and we cannot guarantee absolute security.

9. Cookies and Website Tracking.

We may use cookies or similar tracking technologies to enhance your browsing experience on our website. For more details, please refer to our Cookie Policy.

10. Third-Party Links

Our website or communications may include links to third-party websites. We are not responsible for their privacy practices, so we encourage you to review their policies.

11. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data rights, please contact:

Alan Newton / NewtonSquared Ltd.
Devonshire House, 582 Honeypot Lane, Stanmore, Middlesex, United Kingdom, HA7 1JR.

alan@newtonsquared.com

12. Complaints

If you are dissatisfied with how we handle your personal data, you can contact us in the first instance. If you remain unsatisfied, you can lodge a complaint with the Information Commissioner’s Office (ICO) at https://ico.org.uk/.

13. Updates to This Privacy Policy

We may update this Privacy Policy from time to time. Any significant changes will be communicated to you, and the latest version will always be available on our website or upon request.