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Privacy Policy

Last updated: 10th September 2026

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DC² Divorce Coaching ("DC²", "we", "us" or "our") is committed to protecting your privacy and handling your personal information responsibly.

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This Privacy Policy explains what personal information we collect, why we use it, how it is stored and shared, how long we retain it, and your rights under applicable UK data protection law, including the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018.

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1. Who We Are

DC² Divorce Coaching provides divorce and separation coaching and related practical support.

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For the purposes of UK data protection law, DC² Divorce Coaching is the data controller for the personal information described in this Privacy Policy.

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If you have questions about this Privacy Policy or how your information is handled, please contact:

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Email: doris@dc2divorcecoaching.co.uk
Website: www.dc2divorcecoaching.co.uk

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2. Personal Information We Collect

2.1 Information You Provide Directly

 

Depending on the services you use, we may collect and process:

  • Identity and contact information, such as your name, email address and telephone number.

  • Information relating to your divorce or separation, including information about your circumstances, family arrangements and the issues for which you are seeking support.

  • Documents and supporting information you choose to provide for coaching or practical support. This may include financial disclosure and Form E documentation, correspondence, court or legal documents, and other records relevant to the support you have requested.

  • Financial information, where relevant to the coaching or practical support being provided. Payment and invoicing information may also be processed through our banking, invoicing or website providers.

  • Session notes, consisting of records we reasonably need to maintain continuity of support, provide our services and meet relevant professional, insurance or legal obligations.

  • Session recordings, transcripts and summaries, where you have separately consented to recording and transcription.

  • Correspondence, including information you provide by email, telephone, WhatsApp or other agreed communication methods.

  • Information about other people, where relevant to your circumstances, such as information relating to a spouse or former partner, children, family members or professionals involved in your case.

 

We ask clients to provide only information that is reasonably necessary for the support they are seeking and, when providing information about another person, to avoid sharing unnecessary personal information.

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2.2 Information Collected Through Our Website
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When you use our website, Wix and associated website services may collect information including:

  • IP address and device information;

  • browser type and website usage information;

  • information submitted through contact, enquiry or booking forms;

  • booking and purchase information; and

  • cookie and analytics information, depending on your cookie preferences.

 

Further information about cookies and similar technologies is provided below.

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2.3 Special Category Data

 

Due to the nature of divorce and separation coaching, clients may choose to share sensitive or "special category" personal data where it is relevant to the support they are seeking.

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This may include information relating to physical or mental health, disability or neurodivergence, racial or ethnic origin, religious or philosophical beliefs, sex life or sexual orientation, or other information falling within the special categories defined by data protection law.

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This information may be shared during coaching sessions, in correspondence, in recordings or transcripts where separately consented to, or within documents you ask us to review.

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We process special category data only where it is relevant and necessary for the purposes for which it is being processed, and where an appropriate lawful basis and condition for processing applies under UK data protection law.

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Where we rely on explicit consent for particular processing, you may withdraw that consent at any time. Withdrawal will not affect processing that took place lawfully before consent was withdrawn.

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3. How and Why We Use Personal Information

 

We may use personal information to:

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  • provide divorce and separation coaching and other agreed support;

  • communicate with you and respond to enquiries;

  • arrange and conduct sessions;

  • review documents or information where you have asked us to do so;

  • undertake agreed work between sessions;

  • maintain appropriate records of our work together;

  • administer bookings, invoices and payments;

  • operate, secure and improve our website and services;

  • comply with legal, regulatory, insurance or professional obligations;

  • establish, exercise or defend legal claims where necessary; and

  • protect the rights, safety and interests of clients, DC² Divorce Coaching or others where legally permitted or required.

 

We do not sell your personal information.

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4. Lawful Bases for Processing

 

Under UK data protection law, we must have a lawful basis for processing personal information.

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Depending on the purpose and circumstances, we may rely upon:

  • Contract – where processing is necessary to provide services you have requested or to take steps at your request before entering into a contract.

  • Legal obligation – where processing is necessary for us to comply with a legal obligation.

  • Legitimate interests – where processing is reasonably necessary for the legitimate operation, administration, security or protection of DC² Divorce Coaching or its clients, provided those interests are not overridden by your rights and interests.

  • Consent – where we have specifically asked you for consent for a particular type of processing.

 

Where we process special category personal data, we also identify an appropriate condition for processing under Article 9 of the UK GDPR.

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5. Communication With Clients

We normally communicate with clients by email, phone call or video call (Google Meet).

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Where a client prefers, we may also communicate through WhatsApp for matters such as arranging sessions, keeping in touch between sessions and communicating in connection with agreed work. Clients can tell us if they would prefer not to use WhatsApp.

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Clients should be aware that communications sent through third-party platforms are also processed by the relevant service provider in accordance with that provider's own privacy and security arrangements.

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6. Recording and Transcription of Sessions

 

With a client's prior explicit consent, DC² Divorce Coaching may use Otter.ai to record and transcribe coaching sessions.

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Otter.ai uses automated and artificial intelligence technologies to provide transcription, meeting summaries and related functionality.

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Recording and transcription are optional. Consent is sought separately and clients may decline without this affecting their ability to access coaching services.

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Clients may withdraw their consent to future recording or transcription at any time by informing DC² Divorce Coaching. Withdrawal of consent does not affect processing that has already taken place lawfully.

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Recordings, transcripts and associated summaries are treated as confidential client information and are retained only for as long as reasonably necessary in accordance with our retention practices.

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7. Use of Artificial Intelligence Tools

 

DC² Divorce Coaching may occasionally use artificial intelligence tools to assist with administrative, organisational, drafting, summarising or analytical tasks connected with its work.

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Where general-purpose AI tools such as ChatGPT or Google Gemini are used, DC² Divorce Coaching does not intentionally provide client names or other direct identifiers. Information is minimised and de-identified as far as reasonably practicable before use, and unnecessary identifying details are not intentionally shared.

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General-purpose AI tools are not used to make automated decisions about clients or to make decisions that have legal or similarly significant effects on them.

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Where an AI-enabled service is used directly to process identifiable client information, such as Otter.ai for consensual recording and transcription, this is addressed separately in this Privacy Policy and appropriate consent is obtained where required.

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8. How We Store and Protect Your Information

 

We take appropriate technical and organisational measures to protect personal information against unauthorised access, disclosure, alteration, loss or misuse.

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Client emails, notes and documents are primarily stored using Google Workspace services, including Gmail and Google Drive. Online meetings are normally conducted using Google Meet.

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Access to business systems and client information is restricted, and account security measures including two-factor authentication are used where available.

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Website enquiries, bookings and purchases may be processed through Wix.

 

Invoices and associated payment information may be processed through our dedicated Monzo Business account.

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Where clients choose to communicate via WhatsApp, relevant communications are also processed through that service.

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No method of electronic storage or communication is completely secure, but we take reasonable steps appropriate to the nature and sensitivity of the information we process.

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9. Sharing Personal Information

 

We do not sell, rent or trade client personal information.

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We may share or permit access to personal information only where reasonably necessary, including with:

  • technology and cloud-service providers used to operate our business, including providers of email, document storage, video meetings, website, booking and communication services;

  • transcription services where you have consented to their use;

  • banking, payment, accounting or invoicing providers;

  • professional advisers, insurers or other service providers where reasonably necessary;

  • law enforcement agencies, courts, regulators or other authorities where disclosure is required or permitted by law; or

  • another person or organisation where you have specifically asked or authorised us to share information.

 

Third-party service providers may process information under their own privacy arrangements and/or under contractual data-protection obligations, depending on the nature of their role.

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We take reasonable steps when selecting and using service providers to ensure appropriate data-protection and security arrangements are in place.

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10. International Transfers

 

Some of the technology and service providers we use operate internationally. As a result, personal information may sometimes be stored, accessed or processed outside the United Kingdom.

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Where this constitutes a restricted international transfer under UK data protection law, we take reasonable steps to ensure that an appropriate lawful transfer mechanism or safeguard is in place, such as applicable adequacy regulations or recognised contractual safeguards.

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11. Data Retention

 

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected and to meet any applicable legal, professional, insurance or regulatory requirements.

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Different categories of information may need to be retained for different periods. Client records, coaching notes, correspondence, documents, recordings and transcripts are periodically reviewed and securely deleted or anonymised when they are no longer reasonably required.

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Where a client has consented to session recording or transcription, recordings, transcripts and associated summaries will not be retained indefinitely and will be deleted when they are no longer reasonably required, subject to any overriding legal, professional or insurance requirement.

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We aim to avoid retaining personal information, particularly sensitive or special category information, for longer than is necessary.

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12. Cookies and Website Analytics

 

Our website uses cookies and similar technologies to operate correctly and, depending on your preferences, to understand how visitors use the website.

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Cookies that are strictly necessary for the operation and security of the website may be used without consent where permitted by law.

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Where consent is required for non-essential cookies or similar technologies, visitors will be given an opportunity to accept, reject or manage their preferences through the website's cookie controls.

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You can change your cookie preferences through the available website controls and may also be able to manage cookies through your browser settings.

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13. Your Data Protection Rights

 

Depending on the circumstances, you may have the right to:

  • request access to personal information we hold about you;

  • ask us to correct inaccurate or incomplete information;

  • ask us to delete your personal information in certain circumstances;

  • ask us to restrict the processing of your information;

  • object to certain processing;

  • receive certain personal information in a portable format;

  • withdraw consent where processing is based on consent; and

  • complain about the way your personal information has been handled.

 

These rights are subject to the conditions and exemptions provided by data protection law and do not apply in every circumstance.

 

To exercise a data protection right, please contact doris@dc2divorcecoaching.co.uk.

We may need to verify your identity before responding to a request.

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14. Complaints and the Information Commissioner's Office

 

If you have concerns about how your personal information has been handled, please contact us first so that we have an opportunity to address them.

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You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent data protection regulator.

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Information about your data protection rights and how to make a complaint is available at the ICO website.

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15. Children's Information

 

Our coaching services are provided to adults. However, because divorce and separation may involve children, clients may provide information about their children where it is relevant to the support being provided.

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We ask clients to share only information about children that is reasonably necessary. Information relating to children will be treated with particular care and will not be used for unrelated purposes.

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16. Confidentiality and Legal Disclosure

 

Information shared as part of the coaching relationship is treated confidentially.

 

However, confidentiality is not absolute. We may disclose information where required or permitted by law, including where necessary to comply with a court order or legal obligation, or where there is a serious safeguarding concern or another lawful basis for disclosure.

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Where reasonably possible and lawful, we will seek to inform the client before making such a disclosure.

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17. Changes to This Privacy Policy

 

We may update this Privacy Policy from time to time to reflect changes in our services, working practices, technology or legal obligations.

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The date at the top of this page indicates when the Privacy Policy was last updated.

Where a change materially affects how we process existing client information, we will take reasonable steps to bring the change to the attention of affected clients where appropriate.

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18. Contact Us

 

For questions about this Privacy Policy, your personal information or your data protection rights, please contact:

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Doris Cozma, DC² Divorce Coaching
Email: doris@dc2divorcecoaching.co.uk
Website: www.dc2divorcecoaching.co.uk

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