Privacy Policy

COHERA LTD (company number 17407956), trading as COHERA, is the controller of personal information processed through cohera.uk and our coaching services. The privacy lead is Ben Truckell. Registered office: The Old Post Office, 41–43 Market Place, Chippenham, SN15 3HR. Contact hello@cohera.uk.

This notice applies to website visitors, prospective clients, clients, participants in COHERA Couples work, emergency contacts, professional contacts and other people whose information is lawfully received in connection with COHERA. Couples work involves two people and is subject to the separate joint explanation and agreement provided before coaching.

Depending on your relationship with us, this may include identity and contact details; location; enquiry and programme choices; age confirmation; correspondence; booking, payment and account details; coaching notes and reflections; goals, preferences, experiences and feedback; emergency-contact details; and records of consent, complaints and safeguarding decisions.

For chart preparation we may process birth date, birth time and birth place, together with natal-chart placements and interpretations. Birth data and chart information are ordinary personal data in themselves and are not automatically special-category data. Surrounding disclosures about health, mental health, relationships or other protected matters may become special-category data.

Most information comes directly from you through the website, email, discovery call, intake or coaching. We may also receive information from a joint participant, an emergency or professional contact, a payment or form provider, or a person acting lawfully on your behalf. We do not buy personal data for coaching marketing.

We use information to answer enquiries, assess suitability, arrange calls, prepare charts, deliver and administer coaching, communicate between sessions, provide guidebooks and recaps, process payments, manage safeguarding and complaints, protect our systems, meet legal and insurance duties, and improve services without using confidential coaching disclosures for advertising.

For enquiries and discovery calls we rely on steps taken at your request and our legitimate interest in responding. For an agreed coaching service we rely on contract. For invoicing, accounting, legal compliance, safeguarding and defending claims we rely on legal obligation or legitimate interests. Optional testimonials, publicity and direct marketing rely on consent, which can be withdrawn. Security and essential website operation rely on legitimate interests and, where applicable, the strictly necessary PECR exemption.

We use providers appropriate to the activity: Zoho Mail for business email; Google Workspace, Drive and Meet for controlled business communications and records; FormSubmit for enquiry-form delivery; Stripe once live for payment processing; Astro-Seek for chart calculations where required; and AstroLibrary as a chart-reference and interpretation resource, not as an automated decision-maker. Hosting, security and domain services may also process limited technical data. Provider arrangements and locations are reviewed as services change.

Some providers may process information outside the UK. Before making a restricted transfer, COHERA will use an adequacy decision or another lawful transfer mechanism, such as the UK International Data Transfer Agreement or Addendum, together with appropriate contractual, technical and organisational safeguards. We will update this notice if material provider or transfer arrangements change.

We share information only when necessary with the providers above, professional advisers, insurers, regulators, emergency services or legal authorities where required or permitted. Couples information is not automatically available to one participant without the agreed joint basis and boundaries. We do not sell personal information.

Enquiry records are ordinarily retained for 12 months after the last meaningful contact if no service begins. Discovery-call records are ordinarily retained for 24 months. Relevant client and professional-service records are ordinarily retained for at least seven years after the end of the relevant service where required for insurance, legal, contractual or professional record-keeping purposes. Accounting and payment records are retained for the period required by law, normally six years from the end of the relevant financial year. Consent, complaint and safeguarding records are retained for up to seven years where necessary to evidence decisions or defend claims. Other personal information is retained only for as long as reasonably necessary for its purpose.

We use access controls, authentication, least-privilege sharing, secure services and proportionate technical and organisational measures. No internet transmission is completely risk-free, so please avoid putting sensitive information in the public enquiry form.

Some information is necessary to respond to an enquiry, verify that a prospective client is 18 or over, prepare a chart, take payment or deliver an agreed service. If required information is not provided, we may be unable to respond fully, assess suitability, prepare the requested work or provide coaching. Optional information can be withheld without affecting the core service.

COHERA does not make solely automated decisions, including profiling, that produce legal effects or similarly significant effects about you. Chart software and reference tools support human preparation only; coaching decisions remain collaborative and human-led.

COHERA does not record coaching sessions and does not use AI transcription of sessions. We do not use coaching disclosures to train AI systems. Any future recording or AI-assisted workflow would require a separate review, clear information and any consent or other lawful basis required before use.

Subject to legal exceptions, you may request access, correction, deletion, restriction, portability or object to processing, and withdraw consent where consent is the basis. Email hello@cohera.uk. COHERA will acknowledge a data-protection complaint within 30 days, investigate it appropriately and communicate the outcome. You may also complain to the Information Commissioner’s Office.

Marketing, testimonials, publicity and recordings are separate choices and are never required for coaching. The website’s current technology position is explained in our Cookie Notice. Optional marketing communications will be sent only where lawful and can be stopped at any time.

We review this notice when services, suppliers, law or data practices change. Material changes affecting existing clients will be brought to their attention directly where appropriate. The current version and effective date appear on this page, and changes will not retrospectively create new consent.