Privacy and Cookies Policy

Effective date: 27 June 2026

1. Who we are

Awigia Limited, trading as TheBestYou.Coach, is the controller of the personal information described in this policy.

Awigia Limited
Company number: 07142099
Registered office: Oakwood, 1 Northumberland Road, Leamington Spa, England, CV32 6HE
Email: clair.mackenzie@sparklediscovery.com

2. What information we collect

We may collect:

• your name and contact details;
• account, purchase, invoice and payment-status information;
• enquiries, emails, feedback, complaints and customer-support communications;
• coaching, programme and community information;
• health and lifestyle information you choose to share;
• video, audio, images, displayed names, chat messages or questions where a session is recorded;
• website, device, browser, cookie and analytics information; and
• email and marketing preferences and engagement information.

We collect information directly from you, automatically through our website and platforms, and from payment, social-media and communication providers when you interact with them.

Payment providers normally process your full card details. We do not ordinarily receive or store them.

3. How we use information and our lawful bases

We use personal information to:

• respond to enquiries and take steps requested before a contract;
• process purchases and provide products, programmes, memberships and coaching;
• administer accounts, communities, appointments, recordings and customer support;
• send service communications about something you registered for or purchased;
• maintain financial, contractual and business records;
• operate, secure and improve our website and services;
• send marketing where you have consented;
• comply with legal obligations and protect legal rights; and
• investigate complaints.

Depending on the activity, we rely on consent, performance of a contract, steps taken at your request before a contract, legal obligation, or our legitimate interests in operating and protecting the business.

Contact, account and payment information is required when you purchase. Health and lifestyle information is usually voluntary, but choosing not to provide relevant information may limit the coaching or programme support we can provide.

4. Health information

Health information is special-category personal information and receives additional protection.

Where you choose to provide health information for coaching or programme support, our ordinary lawful basis is usually performance of our contract with you and our additional special-category condition is normally your explicit consent.

You may withdraw consent at any time. This will not affect processing already carried out lawfully, but it may limit the support we can provide. Please share only information relevant to the support you are requesting.

We do not use health information for advertising or testimonials without separate, specific permission.

5. Recordings

We record one-to-one coaching calls only where the client has requested or agreed to recording. The recording is made available privately to that client.

Some small-group and mastermind sessions are recorded for replay by the members of that specific group. These recordings may include participant names, voices, images, questions and personal or health information. They are not made available to another cohort, product or the public.

Participants may keep their camera off, change their displayed name, attend without speaking or submit questions privately where those options are available.

Academy and educational recordings that contain only our teaching and no identifiable member contributions may remain in the relevant product or membership library.

If you have a concern about an identifiable contribution in a replay, contact us. We will consider appropriate action, which may include editing, restricting or removing the contribution where reasonably practicable and legally required.

We will obtain separate permission before using an identifiable recording, image, quotation, case study or health-related story for a testimonial or marketing.

6. Marketing

We send marketing only where you have consented to receive it. We do not buy third-party marketing lists.

You can withdraw consent at any time by using the unsubscribe link in an email or contacting us. This will not stop essential service communications about something you registered for or purchased.

We may keep a minimal suppression record so that we continue to respect your opt-out. We do not sell personal information.

7. Cookies and analytics

We use cookies and similar technologies for essential website, login and checkout functions, preferences, analytics and marketing.

Optional analytics and marketing technologies are used only in accordance with your cookie choices. You can accept, reject or change optional cookie settings through the cookie controls on our website.

Our cookie declaration provides details of the current cookies, providers, purposes and durations.

8. Who we share information with

We may share personal information with trusted providers that help us operate the business, including website and course platforms, payment processors, email and communication services, video and audio platforms, analytics and advertising providers, cloud-storage providers, virtual assistants and professional advisers.

They may process information on our instructions or act as separate controllers for their own legal purposes.

We may also disclose information where required by law, to protect legal rights or as part of a business sale or restructuring. We do not sell personal information.

9. International transfers

Some providers may process information outside the UK. Where a restricted international transfer occurs, we use an appropriate legal safeguard, such as UK adequacy regulations, the UK-US data bridge where applicable, the UK International Data Transfer Agreement, an approved contractual addendum or another lawful transfer mechanism. Contact us for further information about applicable safeguards.

10. How long we keep information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including legal, accounting and claims requirements.

• Enquiries: normally up to two years after the last meaningful contact.
• Contracts, invoices and transaction records: normally six years.
• Coaching and programme notes: normally up to six years after support ends.
• One-to-one coaching recordings: while the agreed private client access continues, followed by a reasonable period for administration and secure deletion.
• Small-group and mastermind recordings: while replay access continues for that group, followed by a reasonable period for administration and secure deletion.
• Academy and product recordings containing only our teaching: while they remain part of the relevant membership, programme or product.
• Raw and duplicate recording files: only while reasonably needed for editing, delivery, backup or administration and subject to periodic review.
• Marketing information: until you withdraw consent or it is no longer reasonably required. A minimal suppression record may be kept after opt-out.
• Complaints and legal records: normally up to six years after closure.
• Cookie and analytics information: for the period shown in our cookie controls or the relevant provider information.

Some recording access may be open-ended. We periodically review retained recordings and delete or anonymise information, raw files and duplicate copies that are no longer needed.

11. Security

We use reasonable technical and organisational safeguards, including access controls, passwords, secure platforms and restricted access to sensitive information. No internet or storage system can be guaranteed completely secure.

12. Your rights

Depending on the circumstances, you may have rights to access, correct, erase or restrict your information, object to processing, receive certain information in a portable form, withdraw consent and object to direct marketing.

To exercise a right, email clair.mackenzie@sparklediscovery.com. We may need to verify your identity and will normally respond within one month.

13. Data-protection complaints

You can make a data-protection complaint by emailing clair.mackenzie@sparklediscovery.com. Please explain the issue and how you would like us to address it.

We will acknowledge your complaint within 30 days, investigate it without undue delay, keep you appropriately informed and communicate the outcome.

You may also complain to the Information Commissioner’s Office: ico.org.uk/make-a-complaint.

14. Automated decision-making

We do not make decisions about you that have legal or similarly significant effects based solely on automated processing.

15. Children

Our paid products and services are for adults aged 18 or over. Contact us if you believe a child has provided personal information inappropriately.

16. Changes to this policy

We may update this policy to reflect changes in law, technology, suppliers or our services. The current version will be published with its effective date.