LEGAL
Privacy Policy
Last updated: June 2026 · Positive Strategies, trading name of Melissa Booth-Simonsen · Warrington, Cheshire, UK
Questions? [email protected] · See also: Privacy Policy • Terms of Use • Cookie Policy
I respect your privacy and am committed to protecting your personal data. I am the data controller for the purposes of UK GDPR and the Data Protection Act 2018.
01
Who We Are & How to Contact Us
Data controller: Melissa Booth-Simonsen trading as Positive Strategies, Warrington, Cheshire, UK.
Email: [email protected]
Postal address: 33 Fern Close, Warrington, Cheshire WA3 7NU
You have the right to make a complaint to the Information Commissioner's Office (ICO) at www.ico.org.uk. I would always prefer to address your concerns first please contact me before approaching the ICO.
By providing your data, you confirm you are aged 13 or over. This Site is not directed at children under 13.
02
Data we collect
I may collect and use the following categories of personal data:
Identity data: first name, last name, username or similar identifier
Contact data: email address, postal address, telephone number
Financial data: payment details (processed via Stripe - I do not store card details)
Transaction data: details of products and services you have purchased
Technical data: IP address, browser type, time zone, device information
Profile data: purchases, interests, preferences, survey and quiz responses
Usage data: how you use and navigate the website
Marketing and communications data: your preferences for receiving marketing
Sensitive data: where coaching involves discussion of health and wellbeing, I may collect information relating to health or neurodivergence. I will always seek your explicit consent before doing so.
03
How we collect your data
Directly from you when you fill in forms, purchase a product, subscribe to my email list, take the quiz, download a resource, book coaching, or contact me.
Automatically via cookies and tracking technologies as you interact with the Site. See my Cookie Policy for details.
From third-party platforms I use to deliver services:
GoHighLevel (CRM, email, and website platform)
Stripe (payment processing)
Google Analytics (website analytics)
Meta Pixel (advertising and retargeting)
04
How we use your data
I only use your personal data when the law allows. Legal bases I rely on:
Contract performance - to deliver products or services you have purchased
Legitimate interests - to run and improve my business
Legal obligation - to comply with applicable law
Consent - for marketing and for any sensitive data
PURPOSE
Register you as a customer
Process and deliver your order
Process and deliver your order
Deliver quiz results and free resources
Improve and protect the Site
Improve and protect the Site
Analytics and audience insight
Comply with legal and tax obligation
DATA USED
Identity, Contact
Identity, Contact, Financial, Transaction
Identity, Contact, Profile
Identity, Contact, Profile, Marketing
Technical, Usage
Identity, Contact, Usage
Identity, Contact, Usage
Identity, Contact, Financial, Transaction
Legal Basis
Contract performance
Contract performance; Legitimate interests
Contract performance; Legal obligation
Legitimate interests; Consent
Consent
Legitimate interests
Legitimate interests
Legal obligation
05
Marketing
I will only send you marketing emails where you have given consent, or where you are an existing customer and have not opted out, in accordance with UK PECR.
You can opt out at any time by clicking unsubscribe in any email, or by emailing [email protected]. Opting out does not affect access to products already purchased.
I do not share your personal data with third parties for their own marketing purposes.
06
Sharing your data
I share your data only where necessary, and only with:
Service providers including GoHighLevel, Stripe, Google Analytics, and Meta, who act as data processors on my behalf
Professional advisers such as accountants or legal advisers, where required
Regulatory authorities including HMRC, where required by law
Successors in the event of a sale or restructure of my business
I do not sell your personal data.
07
International transfers
Some service providers (including GoHighLevel, Google, and Meta) are based outside the UK or EEA. Where your data is transferred internationally, I ensure adequate protections are in place - including standard contractual clauses or transfers to countries with adequate protection recognised by the UK government.
Contact me if you would like details of the specific safeguards in place.
08
Data security
I have put in place appropriate technical and organisational measures to prevent your personal data from being accidentally lost, accessed without authorisation, altered, or disclosed.
I have procedures in place to deal with suspected data breaches and will notify you and the ICO where legally required to do so.
09
Data retention
Customer records: 6 years after the end of the customer relationship (HMRC requirement)
Marketing and email list data: while you remain subscribed; removed within 30 days of unsubscribe
Non-customer enquiry data: 2 years from your last engagement
Quiz and free resource data: 2 years from collection unless you become a customer
In some circumstances I may anonymise your data for research or statistical purposes, in which case it may be retained indefinitely.
10
Your rights
Under UK GDPR, you have the following rights:
Access
Request a copy of the personal data I hold about you.
Rectification
Ask me to correct inaccurate or incomplete data
Erasure
Ask me to delete your data in certain circumstances.
Restriction
Ask me to pause processing in certain situations.
Portability
Request your data in a structured, machine-readable format.
Objection
Object to processing based on legitimate interests or for direct marketing.
Withdraw consent
Withdraw consent at any time where that is the basis for processing.
Objection
Complain to the ICO at ico.org.uk.
To exercise any of these rights, contact [email protected]. I will respond within one month.
12
Changes to this policy
I may update this policy from time to time. The "last updated" date at the top of this page will reflect any changes. Continued use of the Site after changes are published constitutes acceptance.
© 2026 Positive Strategies | Melissa Booth-Simonsen. All rights reserved.
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