Cookie Policy<\/a> for full details.<\/span><\/p>\nA note on safeguarding<\/b><\/p>\n
Confidentiality is not absolute. If you share information that indicates a risk of serious harm to a child or vulnerable adult, I may need to pass that information to the appropriate authorities. I will discuss this with you first wherever possible, but I cannot guarantee complete confidentiality in those circumstances.<\/span><\/p>\nWho I share your data with<\/b><\/p>\n
I keep your data confidential and only share it with the following categories of recipients.<\/span><\/p>\nMy processors<\/b><\/p>\n
These are the platforms and people who help me run my business. Each of them processes your data on my behalf, under a written agreement and appropriate security arrangements:<\/span><\/p>\n\n- 123 Reg (Go Daddy) \u2014 business email hosting (incoming email is delivered to Google Workspace)<\/span><\/li>\n
- Google (Gmail, Google Drive) \u2014 emails, documents, file storage<\/span><\/li>\n
- ActiveCampaign (via Campaign Builder Pro, UK) \u2014 email marketing<\/span><\/li>\n
- ThriveCart \u2014 checkout and order processing<\/span><\/li>\n
- Stripe, PayPal \u2014 payment processing<\/span><\/li>\n
- Xero \u2014 invoicing and accounting<\/span><\/li>\n
- Dropbox and Dropbox Sign \u2014 document storage and signing<\/span><\/li>\n
- Acuity Scheduling (Squarespace) \u2014 appointment booking<\/span><\/li>\n
- TidyCal \u2014 appointment booking<\/span><\/li>\n
- MemberVault \u2014 course delivery<\/span><\/li>\n
- Skool \u2014 community platform (She Can Divorce)<\/span><\/li>\n
- WhatsApp, Voxer \u2014 direct client communication where applicable<\/span><\/li>\n
- WP Engine \u2014 website hosting<\/span><\/li>\n
- An Online Business Manager \u2014 a contracted business support professional who may access my email and systems to help administer client correspondence. She works under a written data processing agreement with confidentiality, security, and data deletion obligations.<\/span><\/li>\n<\/ul>\n
Professional advisers<\/b><\/p>\n
My accountant, and if required my legal and insurance advisers.<\/span><\/p>\nAuthorities<\/b><\/p>\n
If I am legally required to share information, or if safeguarding concerns arise as described above.<\/span><\/p>\nI do not sell your personal data. I do not share it for any other organisation’s marketing purposes.<\/span><\/p>\nInternational transfers<\/b><\/p>\n
Several of my processors are based outside the United Kingdom, primarily in the United States. Where this is the case, I rely on one of the following safeguards to protect your data:<\/span><\/p>\n\n- The UK Extension to the EU-US Data Privacy Framework, for processors certified under that scheme<\/span><\/li>\n
- The UK’s International Data Transfer Agreement (IDTA), or Standard Contractual Clauses with the UK Addendum<\/span><\/li>\n
- A UK adequacy decision, where one applies (for example Switzerland)<\/span><\/li>\n<\/ul>\n
My Online Business Manager accesses my systems from Turkey, which does not have a UK adequacy decision. This transfer is covered by an IDTA between us.<\/span><\/p>\nHow long I keep your data<\/b><\/p>\n
\u00a0<\/span><\/p>\n\n\n\n| \n Data<\/b><\/p>\n<\/th>\n | \n Retention period<\/b><\/p>\n<\/th>\n<\/tr>\n<\/thead>\n\n\n| \n Client emails and correspondence<\/span><\/p>\n<\/td>\n | \n 6 years from the end of our working relationship<\/span><\/p>\n<\/td>\n<\/tr>\n\n| \n Engagement terms and signed agreements<\/span><\/p>\n<\/td>\n | \n 6 years from the end of the contract<\/span><\/p>\n<\/td>\n<\/tr>\n\n| \n Invoices and financial records<\/span><\/p>\n<\/td>\n | \n 6 years from the end of the relevant accounting period<\/span><\/p>\n<\/td>\n<\/tr>\n\n| \n Enquiries that did not become clients<\/span><\/p>\n<\/td>\n | \n 12 months from last contact<\/span><\/p>\n<\/td>\n<\/tr>\n\n| \n Marketing contacts<\/span><\/p>\n<\/td>\n | \n While your consent remains valid, reviewed every 2 years<\/span><\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\u00a0<\/span><\/p>\nI count the end of the working relationship as the earlier of a clear ending or six months with no substantive contact. After these periods, data is securely deleted or anonymised.<\/span><\/p>\nYou have the right to ask me to delete your data sooner. See “Your rights” below.<\/span><\/p>\nHow I keep your data secure<\/b><\/p>\n I have appropriate technical and organisational measures in place, including:<\/span><\/p>\n\n- Two-factor authentication on all business accounts<\/span><\/li>\n
- Strong unique passwords stored in an encrypted password manager<\/span><\/li>\n
- Passcode protection on all devices<\/span><\/li>\n
- A written data processing agreement with my Online Business Manager<\/span><\/li>\n
- No client data stored on shared or unsecured devices<\/span><\/li>\n
- A documented breach response procedure<\/span><\/li>\n<\/ul>\n
If a personal data breach occurs that is likely to affect you, I will notify you and the ICO within the timeframes required by law.<\/span><\/p>\nAutomated decision-making<\/b><\/p>\n I do not carry out solely automated decision-making, including profiling, that produces legal or similarly significant effects on you. If this changes, I will update this policy and let you know.<\/span><\/p>\nYour rights<\/b><\/p>\n Under UK GDPR you have the following rights:<\/span><\/p>\n\n- Access \u2014 to receive a copy of the personal data I hold about you<\/span><\/li>\n
- Rectification \u2014 to have inaccurate data corrected<\/span><\/li>\n
- Erasure \u2014 to have your data deleted, subject to any legal obligation I have to retain it<\/span><\/li>\n
- Restriction \u2014 to restrict how I process your data<\/span><\/li>\n
- Portability \u2014 to receive your data in a portable format<\/span><\/li>\n
- Objection \u2014 to object to processing based on legitimate interests<\/span><\/li>\n
- Withdrawal of consent \u2014 where I rely on consent, you can withdraw it at any time<\/span><\/li>\n<\/ul>\n
\u00a0<\/span><\/p>\nTo exercise any of these rights, please email me at emma@emmaheptonstall.com.<\/span><\/p>\nI will respond within one month. If your request is complex I may extend this by a further two months, in which case I will tell you why. I may need to verify your identity before responding.<\/span><\/p>\nThere is no fee unless your request is manifestly unfounded or excessive.<\/span><\/p>\nHow to complain about how I handle your personal data<\/b><\/p>\n If you are unhappy with how I have handled your personal data, I encourage you to come to me first \u2014 though you have the right to go directly to the ICO at any time without doing so.<\/span><\/p>\nTo complain to me directly<\/b><\/p>\n Email me at emma@emmaheptonstall.com with:<\/span><\/p>\n\n- Your name and contact details<\/span><\/li>\n
- A description of what you believe went wrong<\/span><\/li>\n
- Any relevant dates or context<\/span><\/li>\n
- The outcome you are looking for, if you have one in mind<\/span><\/li>\n<\/ul>\n
I will acknowledge your complaint within 30 days, investigate it properly, and aim to provide a full response within three months. If exceptional circumstances mean I need longer, I will tell you and explain why.<\/span><\/p>\nIf you are not satisfied<\/b><\/p>\n If you remain dissatisfied with my response, or if I have not resolved your complaint within three months, you have the right to escalate to the Information Commissioner’s Office. You also retain this right from the outset \u2014 there is no requirement to come to me first.<\/span><\/p>\n\n- Website: ico.org.uk\/make-a-complaint<\/span><\/li>\n
- Telephone: 0303 123 1113<\/span><\/li>\n
- Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF<\/span><\/li>\n<\/ul>\n
\u00a0<\/span><\/p>\nYou also retain the right to apply to a court for a remedy under UK GDPR.<\/span><\/p>\nChildren<\/b><\/p>\n My services are aimed at adults. I do not knowingly collect personal data from anyone under 18. If you believe a child has provided me with personal data, please contact me and I will delete it.<\/span><\/p>\nCookies<\/b><\/p>\n My website uses cookies for essential functions, analytics, and to remember your preferences. See my Cookie Policy<\/a> for full details and to manage your preferences.<\/span><\/p>\nChanges to this policy<\/b><\/p>\n I review this policy annually and update it when the law changes or when my business changes how it handles data. The version date at the top tells you when it was last updated. Material changes will be flagged on my website.<\/span><\/p>\nContact<\/b><\/p>\n For any questions about this policy or about how I handle your personal data, please email me at emma@emmaheptonstall.com.<\/span><\/p>\n\u00a0<\/span><\/p>\n\n <\/p>\n \n \n \n \n [\/et_pb_text][\/et_pb_column][\/et_pb_row][\/et_pb_section]<\/p>\n","protected":false},"excerpt":{"rendered":" Privacy Policy Emma Heptonstall Ltd, trading as The Divorce Alchemist Last updated: June 2026 About this policy This policy explains how I collect, use, and protect your personal data when you visit my website, contact me, work with me, or join my community. I have written it in plain language so you can understand exactly […]<\/p>\n","protected":false},"author":3,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"_et_pb_use_builder":"on","_et_pb_old_content":" Emma Heptonstall Divorce Coaching for smart women is brought to you by Emma Heptonstall Ltd.<\/span><\/p>Emma Heptonstall Ltd is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.<\/span><\/p>Emma Heptonstall Ltd may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 22.02.2015<\/span><\/p>We may collect certain information about you in the course of your use of this website that we provide to you. We take privacy and security of your information seriously and will only use such personal information as set out in this privacy policy. By using Emma Heptonstall Divorce Coaching for Smart Women website and submitting your information to us you agree to us using your personal information in accordance with this policy.<\/span><\/p>What information will we collect about you?
<\/strong>When you visit, register or order products or services on www.emmaheptonstall.com you may be asked to provide certain information about yourself including your name, contact details and credit or debit card information. We may also collect information about your usage of our website as well as information about you from messages you post to the website and e-mails or letters you send to us.<\/span><\/p>
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