This policy explains how personal information is collected, used and protected when you join or participate in the Dare to Speak Community.

It should be read alongside the general privacy policy at https://evestanway.co.uk.

1. Who is responsible for your information

Dare to Speak is operated by Eve Stanway Coaching and Consulting Ltd, registered in England and Wales under company number 15902522.

Registered office:

International House

64 Nile Street

London

N1 7SR

Eve Stanway Coaching and Consulting Ltd is the data controller for the personal information described in this policy.

ICO registration number: ZB820682

Email: [email protected]

Website: https://evestanway.co.uk

2. The information we collect

We may collect and use:

- your name and email address;

- your contact details;

- your chosen community name or pseudonym;

- your account and profile information;

- your membership plan and membership status;

- payment and transaction information;

- posts, questions, comments and messages you choose to share;

- files, photographs or other content you upload;

- your voice, image, display name and contributions during recorded live sessions;

- information about your use of courses, events and community resources;

- information needed to administer the Monthly Community Contribution Award or referral reward;

- communications you send to Eve or the support team; and

- technical information, including login records, device information, IP addresses and cookies.

Stripe processes your full card details. We do not normally receive or store your complete payment card number.

3. Sensitive information

Conversations about separation, divorce, break-up and co-parenting may reveal sensitive personal information.

This could include information about:

- physical or mental health;

- neurodivergence;

- sexual orientation;

- relationships and family circumstances;

- religious or philosophical beliefs;

- allegations of abuse or harmful behaviour;

- court proceedings; or

- children and other family members.

You choose what you share with the community. Please share only what is necessary and what you feel comfortable disclosing.

Avoid posting unnecessary identifying information about children, former partners or other people.

Where sensitive information is processed, we will use an additional lawful condition permitted under UK data-protection law. This may include your explicit consent, information you have deliberately made public, the protection of someone’s vital interests, or the establishment or defence of legal claims.

4. How we use your information

We use personal information to:

- create and manage your account;

- process and confirm membership payments;

- provide access to the community, courses and resources;

- communicate with you about your membership;

- run live sessions, discussions and community activities;

- answer your questions and provide support;

- moderate the community and enforce the Community Guidelines;

- administer the Monthly Community Contribution Award;

- verify and administer referral rewards;

- improve the service and understand how members use it;

- protect members and maintain platform security;

- investigate complaints or suspected misuse;

- keep appropriate financial and business records;

- meet legal, regulatory, insurance and safeguarding responsibilities; and

- send marketing communications where you have agreed to receive them or where otherwise permitted by law.

We will not use your personal information for purposes that are incompatible with those described in this policy.

5. Our lawful bases

We normally process your information because:

- it is necessary to provide the membership service under our contract with you;

- we have a legitimate interest in operating, protecting and improving the community;

- we need to comply with a legal or regulatory obligation;

- you have given your consent; or

- it is necessary to protect someone’s vital interests.

Where we rely on legitimate interests, we consider the impact on your privacy and use only the information reasonably required.

You may withdraw consent at any time. This will not affect processing that took place lawfully before consent was withdrawn.

6. Your visible community identity

Your visible community name, profile information and contributions can be seen by other members.

You may use a pseudonym as your visible community name. Your real name, contact information, account details and payment information will remain outside the visible community unless you choose to disclose them.

Your pseudonym must not be used to impersonate another person, mislead members or avoid responsibility for your conduct.

Private messages can be seen by their recipients. They may also be accessed by Eve or authorised staff where reasonably necessary for moderation, member support, safety, security or legal compliance.

7. Information about children and other people

Dare to Speak is available only to members aged 18 or over.

Members may discuss co-parenting, young children, adult children, former partners and other family members. Please avoid sharing identifying information unless it is necessary and appropriate.

Do not upload:

- a child’s full name, address, school or contact details;

- photographs or recordings identifying a child without appropriate permission;

- confidential court, medical or educational records;

- material that you are not legally entitled to share; or

- information that could place someone at risk.

If you provide information about another person, you are responsible for ensuring that you have a lawful and appropriate reason for sharing it.

8. Live-session recordings

Every community live session will be recorded and posted within the member library.

A recording may include your:

- display name;

- voice;

- image;

- questions or comments; and

- contributions made through the session chat.

You may keep your camera switched off, avoid speaking, use a pseudonym or watch the recording later.

Please contact Eve promptly if you are concerned about something included in a recording. We will consider reasonable editing, removal or access restrictions, taking account of other members’ rights and what is technically practicable.

Recordings are available only to members and must not be copied or shared outside the community.

9. Monthly Community Contribution Award

Eve may review members’ posts, questions and comments when selecting the recipient of the Monthly Community Contribution Award.

The decision will be based on the published criteria, including thoughtfulness, relevance, respect for others and practical value.

There is no random draw or automated selection.

The selected member will be contacted by email. Information needed to arrange or gift the coaching session will be used only to administer the award and provide the session.

10. Member referral rewards

Where a member refers someone to Dare to Speak, we may process:

- the referring member’s identity;

- the new member’s identity and membership status;

- the date the new member joined;

- whether the first paid month was completed; and

- information needed to issue the gift card.

We use this information to verify eligibility, prevent duplicate or fraudulent claims and provide the reward.

We will not tell the referring member about the new member’s private circumstances, activity or payment details. We will confirm only whether the referral qualifies for the reward.

11. Systems and service providers

We use trusted service providers to operate Dare to Speak, including:

- GoHighLevel, for the membership platform, community accounts, communications and emails;

- Stripe, for membership payments;

- WordPress, for our website and online forms; and

- Zoom or another notified video provider, for live community sessions.

We may also use professional advisers, accountants, insurers, technical support providers and secure business systems where reasonably necessary.

These providers may process personal information on our behalf or act as separate data controllers for parts of their service.

We do not sell your personal information or provide it to other businesses for their own marketing purposes.

12. When information may be shared

We may share information:

- with service providers needed to operate the community;

- with professional advisers, accountants or insurers;

- where required by law, regulation or a court order;

- to investigate fraud, unlawful activity or a serious breach of the Community Guidelines;

- with law-enforcement, safeguarding or regulatory authorities where necessary; or

- where we reasonably believe someone may be at serious or immediate risk.

Only information reasonably necessary for the relevant purpose will be shared.

13. International transfers

Some service providers may store or process information outside the United Kingdom.

Where data-protection law requires it, recognised safeguards will be used. These may include UK adequacy regulations, approved contractual clauses or another lawful transfer mechanism.

14. How long we keep information

We keep personal information only for as long as reasonably necessary.

In general:

- account and membership records are kept while your account is active and for a reasonable period afterwards;

- financial and transaction records are generally retained for six years where required for accounting, tax or legal purposes;

- community posts and comments may remain under your visible name or pseudonym after your membership ends;

- live-session recordings may remain in the member library while they continue to support the service;

- referral and award records are retained for administration, accounting and fraud-prevention purposes; and

- information may be kept for longer where required for a complaint, dispute, safeguarding concern or legal obligation.

15. Deleting community contributions

You may ask us to delete a post, comment or other contribution.

We will consider your request in accordance with data-protection law. There may be circumstances where limited information needs to be retained, including:

- where another person’s rights are affected;

- where information is needed to manage a complaint or legal claim;

- where there is a safeguarding concern;

- where retention is required by law; or

- where information remains temporarily within secure backups until those backups are overwritten.

Deleting a contribution may not remove copies already made unlawfully by another member.

16. Security

We use reasonable technical and organisational measures to protect personal information.

Access is restricted to people who need the information to operate the community, provide support or meet legal responsibilities.

No online platform can be completely secure. You are responsible for keeping your password confidential and protecting access to your account.

Please contact [email protected] promptly if you believe your account or personal information has been compromised.

17. Marketing communications

Service messages about your account, payments, sessions, security or changes to the membership are part of providing the service and cannot always be opted out of while you remain a member.

Marketing communications will be sent only where permitted by law. You may unsubscribe from marketing at any time by using the link in the email or contacting [email protected].

Unsubscribing from marketing will not end your membership or prevent essential service messages.

18. Cookies

The website and membership platform use essential cookies for login, security, account management and basic platform functions.

Where non-essential analytics, advertising or marketing cookies are used, you will be given appropriate choices before they are set.

Further information is available in the cookie information published on https://evestanway.co.uk.

19. Your data-protection rights

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

- ask for a copy of your personal information;

- correct inaccurate or incomplete information;

- request deletion;

- request that processing is restricted;

- object to certain uses of your information;

- receive information in a portable format;

- withdraw consent; and

- complain about how your information has been used.

Some rights are subject to legal exemptions.

We may need to verify your identity before responding to a request. We will normally respond within the period required by data-protection law.

To exercise your rights, email [email protected].

20. Complaints

Please contact Eve first so that we have an opportunity to address your concern:

Email: [email protected]

You also have the right to complain to the Information Commissioner’s Office:

Website: https://ico.org.uk

21. Changes to this policy

We may update this policy to reflect changes to Dare to Speak, our service providers, the law or accepted practice.

The current version will be published on https://join.evestanway.co.uk. Members will be informed of material changes by email or through an announcement within the community.

Questions about this policy or how your information is handled may be sent to [email protected].