Last Updated: 26/07/26
This Privacy Statement describes how FLUENCY CODE LTD (trading as “David De’ Ath”, “The Fluency Code”, and “English Speaking Gym”) (“we”, “us”, or “our”) collects, uses, and discloses your personal information when you visit https://fluencycode.com (the “Site”), participate in our coaching programs, or otherwise interact with us.
1. IMPORTANT NOTICE: NOT LEGAL ADVICE
The information provided in this Privacy Statement is for informational purposes only and does not constitute legal advice. For specific legal concerns regarding data protection and privacy regulations in your jurisdiction, you should consult with a qualified legal professional.
2. INFORMATION WE COLLECT
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our services, when you participate in activities on the Site, or when you contact us.
- Contact Data: Includes your name, email address, and professional title.
- Payment Data: We collect data necessary to process your payment if you make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is stored by our third-party payment processors (e.g., Stripe).
- Coaching Data: To provide our services, we may collect information shared during coaching sessions, including session recordings, notes, assessments of your speaking ability, and professional goals.
- Technical Data: Includes your IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Site.
- Usage Data: Includes information about how you use our Site, products, and services.
3. HOW WE USE YOUR INFORMATION
We use your personal information for several business purposes, including:
- To Provide Services: Delivering coaching programs (such as The Fluency Code and English Speaking Gym), managing your account, and providing customer support.
- To Communicate: Sending you administrative information, updates about your sessions, and marketing communications (where you have consented to receive them).
- To Improve Our Offerings: Analyzing usage data to improve our coaching methodology, website performance, and user experience.
- For Security: Monitoring for potential fraud or unauthorized access to protect our business and our clients.
4. LEGAL BASIS FOR PROCESSING (FOR UK/EU VISITORS)
If you are located in the UK or the European Economic Area (EEA), we process your information under the following legal bases:
- Performance of a Contract: Where we need to process your data to fulfill our coaching agreement with you.
- Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Consent: Where you have given us clear consent to process your personal data for a specific purpose (e.g., marketing).
5. DATA SHARING AND DISCLOSURE
We do not sell, rent, or trade your personal information to third parties for marketing purposes. We may share your data with:
- Service Providers: Third-party vendors who perform services for us, such as payment processing (Stripe), email delivery (e.g., Mailchimp), and community platform hosting (Skool).
- Professional Advisors: Lawyers, auditors, or insurers where necessary.
- Legal Obligations: Where required by law, such as to comply with a subpoena or similar legal process.
6. DATA RETENTION
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Statement, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
7. SECURITY MEASURES
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Site is at your own risk.
8. YOUR PRIVACY RIGHTS
Depending on your location, you may have the following rights regarding your personal data:
- Access: The right to request copies of your personal data.
- Correction: The right to request that we correct any information you believe is inaccurate.
- Deletion: The right to request that we erase your personal data under certain conditions.
- Object/Restrict: The right to object to or restrict our processing of your data.
- Withdraw Consent: Where we rely on consent, you have the right to withdraw it at any time.
9. COOKIES AND TRACKING
We may use cookies and similar tracking technologies to access or store information. You can set your browser to refuse all or some browser cookies, but this may affect the functionality of the Site.
10. CONTACT INFORMATION
If you have questions or comments about this Privacy Statement, you may contact us at: support@fluencycode.com