Effective Date: 15 January 2025
Last Updated: 4 September 2026

1. Who we are

NEWTONSQUARED LIMITED (company number 09183316) of 582 Honeypot Lane, Stanmore, Middlesex, HA7 1JS ("NewtonSquared", "we", "us" or "our") is the controller of the personal data described in this Privacy Policy.

We provide strategic advisory, fractional leadership, non-executive director and UK nominated director-related services, founder coaching, Men Under Pressure coaching and related services.

If you have a question about this Policy or how we handle personal data, contact us at alan@newtonsquared.com.

2. Who this Policy covers

This Policy applies to:

• visitors to our website;

• people who contact or enquire with us;

• prospective, current and former clients, including individual coaching clients;

• people who work for or represent our corporate clients, suppliers and partners;

• people who provide testimonials, feedback or references; and

• people who attend our events, workshops or meetings.

This Policy does not cover third-party websites or services that we do not control. Please review their privacy notices before providing them with information.

3. Personal data we collect

The personal data we collect depends on how you interact with us. It may include:

Contact and identity information

Your name, job title, organisation, email address, telephone number, postal address, country, social-media profile or professional biography where you provide it.

Enquiry and relationship information

The content of messages, contact-form submissions, meeting requests, service interests, correspondence, project context, feedback and records of our communications.

Client-service information

Information reasonably needed to deliver Services, such as business plans, commercial information, operational information, professional goals, agreed deliverables, meeting notes, invoices and payment status.

Coaching information

Information that you choose to share in coaching, including your goals, reflections, challenges and actions. In some cases, this may include information about your health, mental wellbeing, relationships or other sensitive matters. Where transcription is used, this information may also include coaching-session transcripts or notes.

Please do not submit sensitive information through a general website contact form unless it is necessary and you are comfortable doing so. You decide what to disclose in coaching. We do not provide therapy, diagnosis or medical treatment.

Payment and transaction information

Information needed to issue invoices, process payment, manage accounts and meet tax or accounting obligations. Card-payment details are generally processed by our payment provider and are not stored by us.

Technical and usage information

Information about how you use our website, such as IP address, device and browser information, pages viewed, referring website, approximate location derived from IP address, and cookie or analytics information where you have consented to non-essential technologies.

4. How we receive personal data

We collect personal data:

• directly from you when you contact us, book, purchase or use Services;

• from a corporate client, colleague, referrer or professional contact where they introduce or involve you in an engagement;

• automatically through our website and cookies, subject to your preferences; and

• from publicly available professional sources where relevant to a legitimate business conversation or engagement.

5. Why we use personal data and our lawful bases

We use personal data only where data-protection law allows us to do so. Depending on the circumstances, we rely on one or more of the following lawful bases:

To respond to enquiries and arrange introductory conversations. We use your contact and enquiry information because it is in our legitimate interests to respond to relevant professional enquiries and develop relationships, or because you have asked us to take steps before entering into a contract.

To provide our services. We use relevant contact, business, project and coaching information to deliver advisory, fractional leadership, NED, nominated-director, coaching and related services. This is usually necessary to perform our contract with you or your organisation.

To manage payments and business records. We use identity, contact and transaction information to issue invoices, receive payments, maintain accounting records and manage our relationship with you. This is necessary to perform a contract, meet legal obligations and manage our business.

To maintain service quality and protect our legal position. We may keep relevant correspondence, service records and feedback to manage engagements, resolve concerns, improve our services and establish, exercise or defend legal claims. This is in our legitimate interests and, where applicable, necessary to comply with legal obligations.

To protect our website and systems. We use limited technical information to secure our website and systems, prevent misuse and maintain business continuity. This is in our legitimate interests and may also be necessary to meet legal obligations.

To publish a testimonial or case study. We will seek your permission before publishing an identifiable testimonial, case study, image, name, role or organisation, unless another clear written agreement applies.

For analytics cookies. We use non-essential analytics only where you have given the relevant consent through our cookie-preference tool.

Where we rely on legitimate interests, we balance those interests against your rights and expectations. You may object to processing based on legitimate interests; see Section 12.

6. Sensitive personal data

Information about health, mental wellbeing, racial or ethnic origin, religion, sexuality, political views, trade-union membership, genetic or biometric data is "special category" personal data under UK data-protection law.

We do not seek this information through ordinary website forms. However, you may choose to share sensitive information during coaching or other conversations.

Where we need to process special-category data, we will identify both:

• a lawful basis under Article 6 UK GDPR; and

• an additional condition under Article 9 UK GDPR.

For individual coaching and Men Under Pressure work, where sensitive information is involved, we will normally seek your explicit consent for the specific purpose of providing the agreed coaching support. You may withdraw that consent at any time, although this may affect our ability to continue providing the relevant Service.

We may also process or disclose limited information where necessary to protect vital interests in a serious and immediate emergency, or where otherwise required or permitted by law.

7. Recording, transcription and AI-assisted tools

We may transcribe coaching sessions as a standard part of service delivery to support accurate follow-up, reflection, action tracking and continuity across the coaching programme. Clients may ask for transcription to be paused or switched off before any session. If transcription is not used, we may make brief manual notes instead.

We may use AI-assisted tools to analyse, summarise or organise coaching-session transcripts and notes where this supports reflection, programme delivery, action tracking or the adjustment of next steps for the client’s own coaching relationship. AI-assisted tools support Alan’s professional judgment and are not used to make decisions solely by automated means.

We use private, access-controlled project environments and take reasonable steps to ensure that client information is not used to train public or general-purpose AI models. Clients may ask for material from a particular session not to be used for AI-assisted analysis; where this happens, we will use an appropriate alternative, such as manual notes and follow-up.

For corporate advisory engagements, recording, transcription or AI-assisted notes may be used where agreed in writing or otherwise notified in the applicable engagement arrangements.

No online system can be guaranteed completely secure, but we take reasonable technical and organisational steps to protect personal data.

8. Who we share personal data with

We may share personal data with carefully selected providers that help us run our business and deliver Services, including categories of providers for:

• website hosting and website analytics;

• email, calendar, cloud storage, note-taking and document management;

• customer relationship management and scheduling;

• accounting, invoicing and payment processing;

• video meetings, transcription and communications;

• AI-assisted analysis, where expressly permitted as described in Section 7;

• professional advisers, insurers, banks and debt-recovery providers; and

• regulators, law-enforcement bodies, courts or other authorities where required by law.

These providers are permitted to process personal data only as necessary to provide services to us or comply with law, and are subject to appropriate contractual or other safeguards.

We do not sell personal data.

9. International transfers

We work with clients globally and some of our service providers may process personal data outside the UK, including in the European Economic Area and the United States.

Where a transfer of personal data is subject to UK data-protection law, we will use an adequacy regulation or another lawful transfer mechanism with appropriate safeguards, such as the UK International Data Transfer Agreement, the UK Addendum to standard contractual clauses, or another mechanism permitted by law.

You may contact us for further information about the safeguards relevant to a particular transfer.

10. How long we keep personal data

We keep personal data only for as long as reasonably necessary for the purpose for which it was collected, including legal, accounting, tax, insurance and dispute-resolution requirements.

General enquiries. If an enquiry does not result in an engagement, we normally retain relevant contact and correspondence information for up to 12 months after our last meaningful contact.

Client contracts and delivery records. We normally retain contracts, project records, correspondence and service-delivery records for six years after an engagement ends, unless a shorter or longer period is justified.

Coaching notes. We normally retain coaching notes for up to six years after the coaching engagement ends. We may agree a shorter period where appropriate, or retain information longer where a legal or dispute-related need applies.

Financial records. We normally retain financial, tax and accounting records for six years from the end of the relevant financial year, or longer where required by law.

Consent and cookie preferences. We retain records of consent and cookie preferences for as long as reasonably necessary to demonstrate and manage those choices, subject to periodic review.

Testimonials and case studies. We retain these until consent is withdrawn or the relevant agreement ends, unless another lawful basis applies.

We may securely delete, anonymise or aggregate information earlier where it is no longer needed. We may retain limited information longer where necessary to establish, exercise or defend legal claims.

11. Security

We use reasonable technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. These measures include access controls, account protections and use of reputable service providers.

No method of transmission or storage is completely secure. Please take care when sending confidential information electronically and contact us if you have a particular security requirement.

12. Your rights

Subject to applicable law, you may have the right to:

• request access to personal data we hold about you;

• request correction of inaccurate or incomplete personal data;

• request deletion of personal data in certain circumstances;

• request restriction of processing in certain circumstances;

• object to processing based on legitimate interests or direct marketing;

• request transfer of certain data to you or another provider where technically feasible;

• withdraw consent at any time where we rely on consent; and

• complain to the UK Information Commissioner’s Office (ICO).

To exercise a right, email alan@newtonsquared.com. We may need to confirm your identity before responding. We will respond within the timescales required by law.

The ICO can be contacted through its website at ico.org.uk or by telephone on 0303 123 1113. We would appreciate the opportunity to address your concern first.

13. Direct marketing

We do not currently operate a newsletter or routine marketing-email programme.

If we introduce one, we will update this Policy and obtain consent where required by law. You will be able to unsubscribe or object to direct marketing at any time.

We may send necessary service, account, payment, booking or administrative communications. These are not marketing communications.

14. Cookies

Our website uses cookies and similar technologies. Our Cookie Policy explains what they are, how we use them and how to manage your preferences.

We will ask for consent before placing non-essential cookies or similar technologies on your device, where required by law.

15. Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes in our services, working practices or legal requirements. The latest version will be published on our website with its revised date.

16. Contact

For privacy questions, requests or concerns, contact:

NEWTONSQUARED LIMITED
582 Honeypot Lane
Stanmore, Middlesex
HA7 1JS
Company number: 09183316
Email: alan@newtonsquared.com