Privacy Policy.

Information We Collect

By using our website and services, you acknowledge the practices described in this Privacy Policy. This acknowledgement is separate from the lawful bases on which we process your data, which are set out below and in the GDPR addendum.

Voluntarily Provided Information

Information you knowingly provide when:

• Contacting us via forms, email, or social platforms
• Booking sessions or discovery calls
• Subscribing to email updates or resources

Automatically Collected Information

This includes browser metadata such as:

• IP address, browser type, device information
• Time and duration of visits
• Aggregate, anonymous usage statistics via Plausible Analytics

Use of Information

We collect and use your information to:

• Deliver coaching services
• Provide booking and communication functionality
• Understand how our site is used and improve it
• Conduct marketing (with your consent)
• Comply with legal and operational obligations

Personal Information

Personal data may include:

• Name, email address
• Session notes or related content
• Booking, communication, or engagement data

Session Recordings

Some sessions may be recorded with your explicit consent for reflection and internal development. These are confidential and not shared without written permission.

Sensitive Information

We do not require you to submit sensitive financial, legal, or medical data. If shared voluntarily, it will be treated as confidential, but we advise caution in submitting highly sensitive content online.

Confidentiality

Coaching conversations and related records are confidential. We disclose them only where required by law, or where there is a serious risk of harm to you or others, consistent with the ICF Code of Ethics, to which the practice adheres.

Third-Party Data Processors

We rely on a small set of established providers across the following categories. The specific provider in each category may change from time to time as our tooling evolves. The categories themselves describe the work for which your data may be processed.

The Clarity Practice is the organisation responsible for your personal data (the data controller under GDPR). The providers in the categories below act as our processors (or data intermediaries under the PDPA): they process data only on our instructions and on our behalf, and are bound by confidentiality and security obligations. We remain accountable for your data regardless of which provider stores or processes it, and the specific provider in any category may change over time.

• Email service and marketing automation. Newsletter delivery and engagement.
• Scheduling. Booking discovery calls and coaching sessions.
• Customer relationship management (CRM). Client records and engagement workflows.
• Productivity and collaboration suite. Internal communication, documentation, and file storage.
• Website analytics. Aggregate usage analysis and behaviour tracking.
• Meeting recording and transcription. With your explicit consent, on selected sessions only.
• Payment processing. Where applicable, for workshop or programme fees.
• Cloud hosting and storage. Secure storage of records, files, and session documentation.
• AI assistance and document processing. Analysis, summarisation, and preparation of engagement material.

A current list of named providers is available on written request to [email protected].

Data Security

We use commercially acceptable means to protect data against loss, misuse, unauthorised access, or disclosure. However, no method of online transmission or storage is 100% secure.

Data Breach Notification

If a data breach occurs that is likely to result in significant harm to affected individuals, or that meets the notification threshold under the PDPA, we will assess it promptly and notify the Personal Data Protection Commission (PDPC) and affected individuals as required by law. Where the GDPR applies, we will also notify the relevant supervisory authority within the timeframes it sets.

Cookies & Analytics

We keep tracking to a minimum. Our website analytics are provided by Plausible Analytics, a privacy-first, cookieless tool. Plausible does not use cookies, does not store personal data, and does not create persistent identifiers or track you across sites or sessions. Because no personal data is collected and nothing is stored on your device for tracking, we do not display a cookie consent banner.

The only cookies that may be set are strictly necessary ones used by our hosting and security provider to deliver the site securely. These do not track you and are exempt from consent requirements.

If we ever introduce analytics or embedded tools that set non-essential cookies, we will add a consent mechanism before doing so.

Data Retention

We retain personal information only as long as needed for:

• Active coaching relationships
• Marketing opt-ins
• Legal, tax, or compliance obligations

When no longer required, we delete or anonymise personal data.

Your Rights Under Singapore PDPA

You have the right to:

• Access and correct your personal data
• Withdraw consent at any time
• Request deletion of personal data (where allowed by law)
• Opt-out of marketing communications

To exercise these rights, contact us at [email protected].

Children's Privacy

We do not knowingly collect personal information from individuals under 18. If you are under 18, you may only use our services with parental or guardian consent.

External Links

Our website may link to external content or services. We are not responsible for their privacy practices. Please review their own privacy policies before use.

International Data Transfers

Some of your data may be stored or processed in countries outside Singapore (for example, the EU or US). We ensure all vendors meet appropriate data protection standards in line with PDPA obligations.

Business Transfers

In the event of a merger, acquisition, or sale, personal data may be transferred to the acquiring entity, under conditions that protect your privacy.

Complaints & Enforcement

If you believe your data has been misused or your rights infringed, you may:

• Contact us directly at [email protected]
• File a complaint with the Personal Data Protection Commission (PDPC) at pdpc.gov.sg

Policy Updates

We may update this Privacy Policy from time to time. Changes will be published on this page and take effect upon posting.

GDPR Addendum (for EU Visitors)

If you are a resident of the EU, the following applies:

• We are the Data Controller of your personal information.
• Legal bases for processing include your consent, legitimate interest, and contract fulfilment.
• You have the right to access, correct, export, or delete your data.
• You may request restriction or object to processing.
• For data exported outside the EU, appropriate safeguards are in place per GDPR Article 46.
• Coaching may involve information you choose to share that is sensitive (special-category data under Article 9). We process such information only with your explicit consent or another lawful basis, and treat it as strictly confidential.
• You have the right to lodge a complaint with your local EU data protection supervisory authority.

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Thank you for trusting The Clarity Practice®.