Privacy Policy

Last Updated: July 20, 2026

This Privacy Policy explains how Andreev Consulting LTD, trading as New Coaching Clients ("we," "us," or "our"), collects, uses, shares, and protects personal data when you visit present.newcoachingclients.com or newcoachingclients.com (the "Site"), book a call with us, or otherwise interact with our services.

We are a UK company advertising primarily to visitors in the United States and Canada, so this policy is built to the stricter UK GDPR standard as its baseline, with additional US-specific disclosures (CAN-SPAM, CCPA/CPRA-style rights) layered on top.

1. Who We Are (Data Controller)

Andreev Consulting LTD Company registered in England and Wales — Company Number: 14031987 Registered Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom Contact (privacy requests): alex@newcoachingclients.com Trading as: New Coaching Clients

We are the "data controller" for the personal data described in this policy, meaning we decide how and why it is processed. For advertising data collected via the Meta Pixel, Meta Platforms, Inc. acts as a joint controller alongside us for certain "Event Data" (see Section 5).

UK supervisory authority: If you have concerns about how we handle your data, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO): Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom — ico.org.uk

2. What Personal Data We Collect

• Contact information: name, email address, phone number (collected via our booking form)
• Booking details: date, time, time zone, and any responses to intake questions when you schedule a Clarity Call
• Call notes: information you share with us during a consultation call
• Technical and usage data: IP address, browser type, device information, pages visited, referral source
• Advertising identifiers: Meta Pixel cookies (_fbp, _fbc) and related event data (e.g., page view, lead, booking events) when you arrive from, or interact with, a Facebook or Instagram ad
• Email engagement data: via MailerLite, this includes email address, name, and engagement data such as opens/clicks, plus the IP address and timestamp at signup (retained as evidence of consent)

3. How We Collect It

• Directly from you — when you fill out a form or book a call, or share information during a call
• Automatically — through cookies and similar technologies on the Site
• Through the Meta Pixel — a tracking tool provided by Meta Platforms, Inc., which helps us measure ad performance, build advertising audiences, and show relevant ads to people who may be interested in our services. For UK/EU visitors, the Pixel and other non-essential cookies only load after you provide consent via our cookie banner.

4. Why We Process Your Data (Purposes & Legal Bases)

Under UK GDPR, we rely on one of the following legal bases for each purpose:

Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

5. The Meta Pixel, Custom Audiences & Advertising

We use the Meta Pixel and related tools (including Conversions API) on the Site to measure ad performance, build Custom and Lookalike Audiences, and retarget visitors with relevant ads.

• Meta and Andreev Consulting LTD are joint controllers for the "Event Data" collected via these tools, under Meta's Business Tools Terms and its UK Controller Addendum. Once this data reaches Meta, Meta processes it as an independent controller under its own Data Policy.
• You can control how Meta uses this data for advertising via your Facebook or Instagram Ad Settings (Settings → Ads → Ad Preferences), or via the Digital Advertising Alliance opt-out tool at optout.aboutads.info.
• For visitors in the UK/EU, non-essential cookies including the Pixel are not set until you consent via our cookie banner. For visitors elsewhere, an opt-out mechanism is provided as described above and in Section 8.

6. Third-Party Recipients of Your Data

We do not sell your personal data. We share limited data with the following recipients so we can operate our business:

• Meta Platforms, Inc. (United States) — joint controller for advertising/Pixel data; see Section 5
• Trafft (operated by TMS, based in Serbia) — our booking and scheduling platform; Trafft acts as our data processor under a data processing agreement incorporating Standard Contractual Clauses
• Vimeo — hosts video content on the Site; Vimeo may collect basic viewing data (e.g., IP address, device type) under its own privacy policy
• MailerLite — our email marketing platform, used to send communications to subscribers
• FastComet — our web hosting provider
• Lovable — the platform used to build and serve our landing page

These providers are contractually restricted from using your data for purposes other than providing services to us, except where they act as independent or joint controllers as noted above.

7. International Data Transfers

Because we are a UK company sending data to providers based outside the UK, transfers of personal data occur as follows:

• To Meta (United States): where Meta is enrolled in the UK Extension to the EU-US Data Privacy Framework ("UK-US Data Bridge," in force since 12 October 2023), that framework provides the transfer safeguard. We recommend visitors consult Meta's own Data Policy for its current certification status.
• To Trafft (Serbia): transfers are safeguarded under the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, as reflected in our agreement with Trafft.
• We review these safeguards periodically to confirm they remain valid as our providers' certifications and our agreements are updated.

8. Cookies

Our Site uses the following cookies and similar tracking technologies:

These are advertising and functionality cookies. The Meta Pixel cookies (_fbp, _fbc) are used for measurement, retargeting, and building Custom/Lookalike Audiences — see Section 5.

• If you are in the UK or EU, non-essential cookies (including the Pixel) only load after you actively consent via our cookie banner, and you can withdraw consent or manage preferences at any time.
• If you are in the US or Canada, you can opt out of interest-based advertising via your Facebook/Instagram Ad Settings, the Digital Advertising Alliance opt-out tool at optout.aboutads.info, or by contacting us directly at alex@newcoachingclients.com. Where technically supported, we also honor the Global Privacy Control (GPC) signal.
• You can also control or disable cookies generally through your browser settings, though this may affect how the Site functions.

9. Your Rights

If you are in the UK: under UK GDPR, you have the right to access, rectify, erase, or restrict processing of your data; to data portability; to object to processing (including for direct marketing); to withdraw consent at any time; and to complain to the ICO (contact details in Section 1). We aim to respond to any request within one calendar month.

If you are a California resident: the CCPA/CPRA gives you the right to know what personal information is collected, request its deletion or correction, and opt out of the "sale" or "sharing" of personal information. We do not sell data for money, but Meta Pixel data sharing may constitute "sharing" under CPRA for cross-context behavioral advertising — see Section 8 for how to opt out.

If you are a Canadian resident: PIPEDA and applicable provincial laws give you the right to access, correct, and withdraw consent for the use of your personal information.

Regardless of location, you can exercise any of these rights by contacting us at alex@newcoachingclients.com. We may need to verify your identity before actioning certain requests.

10. Data Retention

We retain personal data only as long as necessary for the purposes described in this policy:

• Booking and call data: retained for as long as needed to deliver our services and for a reasonable period afterward for record-keeping, then deleted or anonymized
• Meta Pixel/cookie data: retained according to the cookie's own duration (see our Cookie Policy), typically up to 90 days for _fbp/_fbc, refreshed on interaction
• Email marketing data (once active): retained until you unsubscribe or until a defined period of inactivity, after which it is removed from active lists
• Financial and legal records: retained for the period required under applicable UK tax and accounting law

11. Data Security

We take reasonable technical and organizational measures to protect your personal data. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

12. Email Marketing (Once Active)

When we begin sending marketing emails via MailerLite:

• For US/Canadian recipients, every commercial email will include accurate sender information, a valid physical postal address, and a clear, working one-click unsubscribe link, honored promptly (in line with CAN-SPAM).
• For UK/EU recipients, we will only send marketing emails with your prior consent, or under the "soft opt-in" (where you are an existing prospect, we market only similar services, and you were offered an opt-out at collection and in every message).
• We maintain a suppression list to honor unsubscribes and opt-outs going forward.

13. Children's Privacy

Our services are not directed to children under 13, and we do not knowingly collect personal information from children under 13. If we become aware that we have inadvertently collected such information, we will delete it promptly.

14. Changes to This Policy

We may update this Privacy Policy from time to time, including when we adopt new tools (such as activating MailerLite) or when applicable law changes. Changes will be posted on this page with an updated "Last Updated" date. We review this policy at least annually.

15. Contact Us

If you have questions about this Privacy Policy or how we handle your data, contact us at:

Andreev Consulting LTD Email: alex@newcoachingclients.com Registered Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom Company Number: 14031987

To complain to our supervisory authority: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom — ico.org.uk