Who this policy is for
This Privacy Policy applies to all users of the Becoming Her App, including individual subscribers and employees of corporate client organisations who access the App as Authorised Users. It explains what personal data we collect, why we collect it, how we use it, and your rights under UK data protection law.
1. Who We Are
Becoming Her is operated by Steven Jackson, trading as Becoming Her and Ora Life Coaching Ltd, registered in England and Wales (company number 16398439).
For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, Steven Jackson trading as Ora Life Coaching Ltd under Becoming Her is the Data Controller in respect of the personal data processed in connection with the App.
Contact: youdefineyou3@gmail.com
Postal address: 37 Market Street, Ferryhill, Co Durham, DL17 8JH
ICO Registration Number: To be confirmed
2. The Data Protection Officer
Data Protection contact: Steven Jackson
Email: youdefineyou3@gmail.com
If you have any questions about how we handle your personal data, or if you wish to exercise any of your rights, please contact us at the address above.
3. What Data We Collect and Why
We collect and process the following categories of personal data in connection with your use of the Becoming Her App:
Account and registration data
When you create an account on the App we collect your name, email address, and a password. This is necessary to create and manage your account and provide you with access to the Programme.
Profile and Programme data
As you work through the Programme, you will complete the Foundation tools (Life Assessment, Limiting Beliefs, Personal Timeline and Triggers) and the daily Thought Diary. This information is personal and is stored privately within your individual account. It is not accessible to any third party, including — where you are an Authorised User of a corporate licence — your employer, HR team or line manager.
Payment data
Where you purchase a subscription directly, payment is processed by Stripe. We do not store your full card details. Stripe processes your payment data as a data processor on our behalf. Please refer to the Stripe Privacy Policy for full details of how Stripe handles your payment data.
Usage and technical data
We may collect technical data about how you use the App, including login times, pages visited within the App, and device information. This is used to maintain and improve the App and ensure it functions correctly.
Communications data
If you contact us by email or otherwise, we will retain a record of that communication in order to respond to your query and for record-keeping purposes.
Email marketing data
Where you have opted in to receive email communications from us, your name and email address will be stored and managed via Kajabi. You can unsubscribe from marketing emails at any time by clicking the unsubscribe link in any email or by contacting us directly.
4. Legal Basis for Processing
We process your personal data on the following legal bases under the UK GDPR:
- Contract — processing necessary to provide you with the App and Programme you have signed up for, including account management, Programme delivery and payment processing.
- Legitimate interests — processing necessary for our legitimate interests in maintaining and improving the App, communicating with users, and protecting the security of our services, where those interests are not overridden by your rights.
- Consent — where you have given your consent, for example to receive email marketing communications. You may withdraw your consent at any time.
- Legal obligation — where we are required to process your data to comply with a legal obligation.
5. How We Use Your Data
We use your personal data for the following purposes:
- To create and manage your App account.
- To provide you with access to the Becoming Her Programme, tools and content.
- To process payments where applicable.
- To send you transactional communications relating to your account, including confirmation of sign-up, password resets and important updates about the App or Programme.
- To send you marketing communications where you have opted in to receive them.
- To maintain, improve and develop the App.
- To respond to any queries or complaints you raise with us.
- To comply with our legal and regulatory obligations.
6. Your Data Is Private
Your in-App content belongs to you and is visible only to you.
Everything you enter into your private account — your Foundation, your Thought Diary, your Limiting Beliefs, your Personal Timeline — is stored privately within your individual account. It is not read, accessed, analysed or shared by Becoming Her or any third party, except as required by law or in the circumstances described in Section 10 of this Policy.
Where you access the App as an Authorised User under a corporate licence, your employer, HR team, managers and colleagues have no access to your in-App data whatsoever. This privacy is absolute and is fundamental to how the App works.
7. Third-Party Processors
We work with the following third-party service providers who may process your personal data on our behalf as data processors. All processors are required to handle your data securely and in accordance with applicable data protection law.
| Provider | Purpose | Location | Privacy Policy |
|---|---|---|---|
| Stripe | Payment processing for subscriptions and purchases | USA / UK | stripe.com/gb/privacy |
| Kajabi | Email marketing and communications platform | USA | kajabi.com/privacy |
| Claude (Anthropic) | AI coaching tool: processes conversation data you actively share with the AI Tool in order to generate responses | USA | anthropic.com/legal/privacy |
| Team Marvel | Technical hosting and platform management | UK / Worldwide | Available on request |
Where any of our processors are located outside the UK, we ensure that appropriate safeguards are in place for the transfer of your data, including Standard Contractual Clauses approved by the ICO or reliance on adequacy decisions where applicable.
8. How Long We Keep Your Data
We retain your personal data for as long as necessary to provide you with the App and Programme, and for a period thereafter as required by law or for legitimate business purposes. Specifically:
- Account and Programme data is retained for the duration of your subscription and for 6 years following the end of your subscription, in line with standard legal retention requirements.
- Payment records are retained for 7 years in accordance with HMRC requirements.
- Marketing data is retained until you unsubscribe or request deletion.
- Communications data is retained for 3 years from the date of the communication.
9. Your Rights
Under the UK GDPR you have the following rights in relation to your personal data:
- The right to access — you may request a copy of the personal data we hold about you.
- The right to rectification — you may ask us to correct any inaccurate or incomplete personal data we hold about you.
- The right to erasure — you may ask us to delete your personal data in certain circumstances.
- The right to restrict processing — you may ask us to restrict how we process your data in certain circumstances.
- The right to data portability — you may ask us to provide your personal data in a structured, commonly used and machine-readable format.
- The right to object — you may object to our processing of your personal data where we rely on legitimate interests as our legal basis.
- The right to withdraw consent — where we rely on your consent to process your data, you may withdraw that consent at any time.
To exercise any of these rights, please contact us at youdefineyou3@gmail.com. We will respond to all requests within one calendar month. We may need to verify your identity before processing your request.
10. Safeguarding and Disclosures
In the event that information shared by a user gives us reasonable cause to believe that the user or another person is at risk of harm, we reserve the right to disclose such information as is reasonably necessary for the protection of that individual or others, including to appropriate authorities.
We may also be required to disclose personal data where we are subject to a legal obligation to do so, including court orders or regulatory requirements.
11. Cookies
The Becoming Her App may use cookies and similar technologies to maintain your session, remember your preferences and improve the performance of the App. No third-party advertising or tracking cookies are used.
For full details of cookies used please refer to our Cookie Policy.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in the App, our practices, or applicable law. Where we make material changes we will notify users via the App or by email. The date at the top of this Policy indicates when it was last updated.
13. How to Complain
If you are unhappy with how we have handled your personal data, please contact us in the first instance so that we can try to resolve your concern: youdefineyou3@gmail.com.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's data protection supervisory authority:
- Website: ico.org.uk
- Telephone: 0303 123 1113
- Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF