Privacy policy.
Last updated: August 2026
Sal Jefferies Limited (“we”, “us” or “our”) respects your privacy and is committed to protecting your personal information.
This Privacy Policy explains how we collect, use, store and protect personal information when you visit our website, make an enquiry, book a meeting or receive professional coaching from us.
We process personal information in accordance with applicable UK data protection law, including the UK GDPR and Data Protection Act 2018.
1. Who we are
Sal Jefferies Limited is the data controller responsible for the personal information described in this policy.
Company number: 05105650
Registered office: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ
Contact email: ea@saljefferies.com
Sal Jefferies Limited is incorporated in England and Wales.
We have not appointed a formal Data Protection Officer. Responsibility for data protection rests with the Company.
If you have any questions about this policy, how we use your information, or your data protection rights, please contact us at:
2. Information we collect
Depending on how you interact with us, we may collect:
your name and contact details
your job title, company and professional background
information you provide when making an enquiry or booking a meeting
information you provide during a coaching engagement
scheduling and appointment information
correspondence between you and us
invoicing, payment and accounting information
coaching recordings, transcripts and AI-generated notes where you have consented to recording
feedback or testimonials you choose to provide
website and analytics information such as IP address, browser, device and website usage information
We use this information to:
respond to enquiries
arrange and provide coaching
administer the client relationship
invoice for our services
maintain appropriate business records
operate and improve our website
comply with legal and accounting obligations
Our lawful bases may include:
taking steps at your request before entering into a contract
performance of our contract with you
compliance with a legal obligation
our legitimate interests in running and improving a professional coaching business
consent, where consent is the appropriate basis
Where special-category personal information is processed, we also identify an appropriate condition under Article 9 of the UK GDPR. Where Grain recordings may contain special-category information, we may rely on your explicit consent.
3. Coaching confidentiality
Professional coaching conversations may involve personal as well as professional matters.
We regard information shared within the coaching relationship as confidential and do not ordinarily disclose the substance of coaching conversations to third parties without your agreement.
There may be limited circumstances in which disclosure is necessary or permitted, including where:
you ask or authorise us to disclose information
disclosure is required by law
information is required to establish, exercise or defend legal claims
disclosure is reasonably necessary in connection with a serious and imminent risk of harm
trusted technology or professional service providers need to process information in order to provide services to us
Where coaching is commissioned or paid for by an employer or another organisation, any reporting or confidentiality arrangements will normally be agreed in advance.
Unless expressly agreed otherwise, we do not ordinarily disclose detailed content from individual coaching sessions to the organisation paying for the coaching.
4. Grain recording, transcription and AI
For online coaching sessions, we may use Grain, an AI-assisted recording and transcription platform.
We use Grain so that both client and coach can remain fully engaged in the coaching conversation without needing to take extensive written notes.
It also allows both parties to revisit sessions and review insights, actions and progress afterwards.
Where Grain is used, it may create:
an audio and/or video recording
a transcript
AI-generated notes and summaries
key points and agreed actions
other AI-assisted outputs
Your choice
Recording is optional.
Where Grain is being used, you may ask for the session not to be recorded.
You may also ask for recording to stop at any time during a session.
Choosing not to record a session will not affect the coaching service you receive.
Where you have provided explicit consent to the use of Grain as part of your coaching agreement, that consent may remain in place for the duration of the coaching engagement unless you withdraw it.
However, you remain free to opt out of recording for any individual session.
In-person coaching sessions are not recorded using Grain or another AI recording system.
Reviewing progress over time
Where sessions have been recorded with your consent, we may review information from several sessions together.
This allows us to identify themes, patterns, commitments, changes and progress across a coaching engagement lasting several months or longer.
AI tools may assist with this review, but AI-generated observations do not replace the coach’s judgement and are not treated as definitive assessments of the client.
We do not use AI to make solely automated decisions about clients that produce legal or similarly significant effects.
Sensitive information
Coaching conversations can sometimes include sensitive personal information that you choose to disclose, including information about:
health or wellbeing
beliefs
ethnicity
political opinions
trade union membership
sex life
sexual orientation
Some of this information is classified as special-category personal data under UK data protection law.
Where appropriate, we rely on your explicit consent to process such information through Grain’s recording, transcription and AI-assisted functionality.
You can withdraw consent to future processing at any time.
5. Website, bookings and online meetings
Our website is hosted by Squarespace.
Squarespace may process information such as:
IP address
browser and device information
pages visited
website interactions
This helps us operate the website and understand how it is being used.
We also use Google Analytics to understand how visitors find and use our website.
Google Analytics may collect information about:
website sessions
approximate location
device and browser information
interactions with the website
Non-essential analytics cookies are managed through our website’s cookie controls.
Visitors can accept, decline or manage non-essential cookies.
We use TidyCal to manage bookings and appointments.
When you book through TidyCal, information such as your name, email address, appointment details and any information you choose to provide may be processed through that service.
Online coaching sessions normally take place using Zoom.
Zoom may process meeting and participant information in providing its service.
In-person coaching sessions take place at an agreed venue and are not recorded using Grain or another AI recording system.
6. Service providers and international processing
We use trusted third-party providers to operate our business and deliver our services.
These may include providers of:
website hosting and analytics
appointment scheduling
video conferencing
meeting recording and transcription
artificial intelligence services
cloud and technology infrastructure
email
accounting
professional services
These currently include Squarespace, Google Analytics, TidyCal, Zoom and Grain.
Grain may use approved subprocessors, including artificial-intelligence providers, in providing its services.
Some technology providers may store or process personal information outside the United Kingdom.
Where international transfers take place, we take appropriate steps to ensure they are made in accordance with UK data protection law, including recognised adequacy arrangements or appropriate contractual safeguards where applicable.
You may contact us if you would like further information about safeguards relevant to your personal information.
We do not sell your personal information.
We do not use confidential coaching recordings or transcripts for advertising purposes.
7. How long we keep information
We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and to meet legal, accounting and business requirements.
Unsuccessful enquiries
Information relating to enquiries that do not lead to a coaching engagement is normally retained for 24 months.
Grain recordings and related material
Recordings, transcripts and associated AI-generated coaching material are normally retained throughout the active coaching engagement and for 12 months after the coaching relationship ends.
This enables both client and coach to revisit sessions and review the development of the coaching engagement as a whole.
After the 12-month period, Grain recordings, transcripts and related AI-generated material will normally be deleted unless there is a specific lawful reason to retain particular information for longer.
You may request earlier deletion of your Grain recordings and related material.
We encourage you to make such a request by email to:
so that there is a clear record of your request.
Where your right to erasure applies, we will ordinarily delete the relevant information.
The right to erasure is not absolute and, in limited circumstances, we may be legally entitled or required to retain particular information.
Financial, tax, contractual and other business records may be retained for longer where required by law or reasonably necessary for legal or business purposes.
8. Security
We take appropriate technical and organisational measures designed to protect personal information against:
accidental loss
unauthorised access
alteration
disclosure
misuse
These measures include the use of reputable service providers, appropriate access controls, password and account security, confidentiality practices and limiting access to information where appropriate.
Because coaching recordings can contain particularly personal information, we treat recordings, transcripts and related material as confidential client information.
No internet-based service can guarantee absolute security, but we take reasonable measures proportionate to the information we process.
9. Your rights
Depending on the circumstances, UK data protection law gives you rights including:
the right to access personal information we hold about you
the right to correct inaccurate information
the right to request erasure of information in certain circumstances
the right to restrict processing in certain circumstances
the right to object to certain processing
the right to data portability in certain circumstances
the right to withdraw consent where processing is based on consent
Where processing is based on consent, you may withdraw that consent at any time.
Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
You have an absolute right to object to the use of your personal information for direct marketing.
To exercise your rights, contact:
You do not have to use a particular form or wording to exercise your statutory rights, although making a request by email can help us respond efficiently.
10. Complaints
If you have a concern about how we use your information, please contact us at:
We would welcome the opportunity to address your concern.
You also have the right to complain to the Information Commissioner’s Office (ICO), the UK regulator for data protection.
Further information is available at:
ico.org.uk
11. Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in our services, technology or legal obligations.
The current version will be published on our website and the date at the top of this policy will indicate when it was last updated.