Privacy Policy for Clearpath Cognitive Coaching Limited.
Who We Are
Clearpath Cognitive Coaching Limited ("Clearpath," "we," "us," "our") is a Private Company Limited by Shares registered in Ireland (CRO Number: 811903), registered office 6 Blackwood Lawn, Ongar, Dublin 15, D15 T6Y2. We provide Positive Psychology and Coaching, Recovery and Resilience Coaching, Organisational Workplace Mental Health and Wellbeing Coaching, and Emotional Resilience Competencies services. We are the Data Controller for personal data collected through clearpathcognitive.com and through our coaching services. Data protection contact: Info@clearpathcognitive.com.
What Data We Collect
Client data: name, contact details, coaching session notes and wellbeing assessment data (Special Category data under Article 9 GDPR), payment records, and enquiry or booking correspondence. Website data: IP address, browser and device information, and pages visited, collected via analytics and cookies only where you've given consent. Newsletter data: name and email address, collected on the basis of your explicit, withdrawable consent.
How We Use Information and Legal Basis
We use information to respond to enquiries, manage bookings, process payments, deliver coaching-related communication, and meet legal and accounting obligations. Identity, contact and payment data are processed for contract performance and legal obligations. Where special category wellbeing data is needed, explicit consent is obtained before processing. Optional analytics and newsletter communications require consent.
Special Category Data
Coaching session notes and wellbeing assessment information count as Special Category data under Article 9 GDPR. We only process this with your explicit, signed consent, given before your first paid session. You can withdraw that consent at any time; this won't affect the lawfulness of anything already processed.
Service Providers
We work with hosting, email, analytics, payment, and practice management providers to run the website and manage client communication. Each is bound by a data processing agreement and may only use your information to provide their service to us.
Who We Share Your Data With
We don't sell your personal data. We may share it with our practice management software provider, our payment processor (Stripe), our email platform, our clinical supervisor (anonymised case material only), TUSLA where mandatory child-protection reporting applies, courts or regulators where legally required, and our accountant and legal advisor under confidentiality obligations.
Data Retention
Adult client coaching records: 7 years from last contact. Financial and invoice records: 7 years. Newsletter data: until you unsubscribe or after 3 years of inactivity. Website analytics: 26 months.
Your Rights
Under GDPR you can ask to access, correct, or delete your personal data, restrict or object to certain processing, request data portability, and withdraw consent at any time. To exercise any of these, contact us at Info@clearpathcognitive.com. You can also complain to the Data Protection Commission at dataprotection.ie.
Data Security
We use encrypted software and devices, secure cloud storage, and access controls, and we don't send Special Category client data by standard email or messaging apps.
Changes to This Policy
We may update this policy from time to time. The current version is always published at clearpathcognitive.com/privacy-policy.
Need clarification?
Questions about this page can be sent to the Clearpath team.