Privacy Policy
Last updated: May 2026
This privacy policy explains how Empower Academy Limited, trading as B2B Culture Coach, collects, uses, and protects your personal data. We are registered with the Information Commissioner's Office under registration reference ZB962241.
Who we are
Empower Academy Limited, trading as B2B Culture Coach 58 Havers Avenue, Hersham, KT12 4NE.
Company No. 16227999, registered in England and Wales
Email: [email protected] Website: www.b2bculturecoach.com
What personal data we collect
We collect and process the following personal data:
Your name, job title, and company name. Your email address and contact details. Information you share during diagnostic sessions and coaching conversations. Payment information processed through Stripe. Records of your engagement with our programmes and services. Technical data such as IP address and browser type collected automatically when you visit our website.
How we collect your data
We collect personal data when you purchase a product or service through our website. We collect it when you complete an intake or enquiry form. We collect it during diagnostic sessions conducted via Google Meet, which are transcribed automatically. We collect it through email correspondence. We collect it when you interact with our website.
Why we collect your data and our legal basis
We process your personal data for the following purposes:
To deliver the CODE Leadership Diagnostic, coaching programmes, and associated services. Our legal basis is the performance of a contract. To send you information relevant to your programme and progress. Our legal basis is legitimate interests. To issue completion certificates through Certifier. Our legal basis is the performance of a contract. To process payments securely through Stripe and issue invoices through Xero. Our legal basis is the performance of a contract and legal obligation. To manage our client relationship through HubSpot. Our legal basis is legitimate interests. To improve our services and understand how our website is used through Google Analytics. Our legal basis is legitimate interests.
Anonymised data and industry insights
Anonymised and aggregated data from diagnostic sessions may be used to produce industry insights and trends reports. These reports identify patterns across cohorts of leaders and are shared publicly, including on LinkedIn. No personally identifiable information, including your name, job title, company, or any combination of details that could identify you, will ever be included or published. Once data is fully anonymised it falls outside the scope of UK GDPR.
How long we keep your data
We retain client records, including session transcripts and diagnostic reports, for two years following the end of your engagement with us. Payment records are retained for seven years in line with HMRC requirements. You may request deletion of your personal data at any time, subject to our legal obligations to retain certain records.
Who we share your data with
We use the following third party platforms to deliver our services. Each acts as a data processor on our behalf:
Kajabi: website, course delivery, and email communications. Stripe: payment processing. Xero: invoicing and financial records. Google: session transcription, document storage, and website analytics. HubSpot: client relationship management. Certifier: completion certificates. Calendly: session scheduling.
We do not sell your personal data to any third party.
Your rights
Under UK GDPR you have the right to access the personal data we hold about you. You have the right to correct any inaccurate data. You have the right to request deletion of your data. You have the right to object to or restrict how we process your data. You have the right to data portability. To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.
Complaints
If you have concerns about how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner's Office at ico.org.uk or by calling 0303 123 1113.
Changes to this policy
We may update this policy from time to time. The date at the top of this page will always reflect the most recent version.