Last updated: 12 October 2026
Your trust matters as much as your development. This policy explains what personal data we collect, why we use it, who we share it with, and the choices you have. It is written to meet the UK GDPR, the EU General Data Protection Regulation (GDPR) and India’s Digital Personal Data Protection Act 2023.
1. Who is responsible for your data
Finbarr Buckley (Leadership & Career Coaching), Thenzawl, India 796186, is the controller (or “data fiduciary”) of your personal data.
For any privacy question or request, including grievances under Indian law, contact Finbarr Buckley at info@finbarrbuckley.com.
2. What we collect
Information you give us
- Senior Interview Readiness Scorecard: your name, email address and answers, including your current level, when you expect to interview and how long it has been since your last interview.
- Career Clarity Assessment: your name, email address and answers about your interests, values and work style.
- Enquiry and contact forms: your name, email address and anything you choose to tell us.
- Discovery call bookings: your name, email, chosen time and any notes you add, collected through HubSpot.
- Purchases: your name, email, country and what you bought. Razorpay processes your card details; we never see or store them.
- Coaching and workshops: your CV, LinkedIn profile, career goals and the notes we take during sessions, if you share them.
Information collected automatically (only with your consent where the law requires it)
- Pages visited, how you arrived (including UTM campaign tags), device and browser type, approximate location and IP address.
- Interactions with our ads and website, through the Meta pixel and Meta Conversions API.
- Whether you open or click our emails, through MailerLite.
Please don’t share health, financial or other sensitive information with us unless it is relevant to your coaching and you are comfortable doing so.
3. How we use your data and why we’re allowed to
| What we do | Lawful basis (UK/EU GDPR) |
|---|---|
| Send your scorecard or assessment results | Your request (taking steps at your request before a contract) |
| Send our follow-up email series and occasional updates | Your consent, which you can withdraw at any time |
| Reply to enquiries and arrange discovery calls | Taking steps at your request |
| Deliver coaching, workshops and resources you have bought | Performance of our contract with you |
| Process payments and keep financial records | Contract and legal obligation |
| Measure website performance and improve our content | Your consent (analytics cookies) |
| Show you relevant ads on Facebook and Instagram, and measure them | Your consent (marketing cookies) |
| Protect our business and resolve disputes | Legitimate interests |
Under Indian law, we process your data on the basis of your consent or for the specific purpose for which you voluntarily gave it to us.
We do not sell your personal data, and we do not use it for automated decisions that have legal or similarly significant effects on you. Your scorecard score is calculated automatically to show you your results only.
4. Cookies and tracking
Cookies are small files stored on your device. We use:
- Essential cookies: needed for the website, forms and payments to work. These are always on.
- Analytics cookies: show us how visitors use the site so we can improve it.
- Marketing cookies (Meta pixel): help us measure our Facebook and Instagram ads and show our ads to people who have visited our site.
Analytics and marketing cookies only load after you accept them in our cookie banner. You can change your choice at any time through the “Cookie settings” link in the website footer. If you accept marketing cookies, we may also send Meta limited information about actions such as a completed booking, through Meta’s Conversions API. Your email address is encrypted (hashed) before it is sent.
UTM tags are labels in links that tell us which campaign brought you to our site. They do not identify you on their own.
5. Who we share your data with
We share data only with trusted providers who help us run the business, under contracts that require them to protect it:
| Provider | Purpose |
|---|---|
| Razorpay | Payment processing |
| MailerLite | Email delivery and results reports |
| HubSpot | Discovery call booking and contact records |
| Meta Platforms | Advertising and measurement (with your consent) |
| Zoom or a similar platform | Live online sessions |
| Our website host and analytics provider | Running and measuring the website |
| Google (Gmail and Drive) | Email and secure file storage |
We may also share data if the law requires it, or with professional advisers such as accountants under a duty of confidentiality.
6. International transfers
We are based in India, and some of our providers store data in the United States, the European Union or elsewhere. When your data is transferred from the UK or EU to a country without an adequacy decision, we rely on safeguards such as the European Commission’s standard contractual clauses, the UK International Data Transfer Addendum or the EU–US Data Privacy Framework.
7. How long we keep your data
| Data | How long |
|---|---|
| Email subscribers and leads | Until you unsubscribe, or 24 months with no engagement |
| Scorecard and assessment answers | 24 months |
| Enquiries that don’t lead to a booking | 12 months |
| Coaching notes and client records | 6 years after our work together ends |
| Payment and tax records | 8 years, as required by Indian tax law |
| Workshop replay recordings | 30 days after the workshop, then deleted |
After these periods, we delete your data or make it anonymous.
8. Workshop recordings
We record only the teaching segments of live workshops. If you speak or appear on camera during those segments, you may be visible in the replay, which is shared only with that workshop’s attendees for 30 days. Breakout practice is never recorded. If you prefer not to appear, you can turn off your camera during the teaching segments.
9. Your rights
Depending on where you live, you have the right to:
- access the personal data we hold about you;
- correct inaccurate or incomplete data;
- have your data erased;
- withdraw consent at any time, without affecting earlier processing;
- object to or restrict how we use your data, including for marketing;
- receive your data in a portable format;
- in India, nominate another person to exercise your rights if you die or become incapacitated, and have your grievances addressed.
Every email we send has an unsubscribe link. For any other request, email info@finbarrbuckley.com. We will respond within one month, and usually much sooner.
10. Complaints
Please contact us first so we can try to put things right. You also have the right to complain to your data protection authority:
- UK: Information Commissioner’s Office (ico.org.uk)
- Ireland: Data Protection Commission (dataprotection.ie)
- Other EU countries: your national supervisory authority
- India: the Data Protection Board of India, once you have used our grievance process
11. Keeping your data secure
We use reputable providers with strong security, keep access limited to Finbarr Buckley, and use secure passwords and two-factor authentication. No online system is completely secure, but we will tell you and the relevant authority promptly if a breach affects your data, as the law requires.
12. Children
Our services are for adults. We do not knowingly collect data from anyone under 18.
13. Changes to this policy
We may update this policy as our services or the law change. The “Last updated” date shows the latest version. We will email you about any significant change that affects how we use your data.
14. Contact us
Finbarr Buckley (Leadership & Career Coaching)
Thenzawl, India 796186
info@finbarrbuckley.com