Website Privacy Notice

Last updated: 1st June 2026

1. Introduction

Who we are

This privacy policy covers the websites ClareJosa.com, DitchingImposterSyndrome.com, and SoultuitiveLeadership.com, and all work carried out by Soultuitive Leadership Ltd and Clare Josa on its behalf.

This privacy notice provides you with details of how we collect and process your personal data through your use of our sites.

By providing us with your data, you warrant to us that you are over 13 years of age.

Soultuitive Leadership Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details

Our full details are:

Full name of legal entity: Soultuitive Leadership Ltd

You can contact us here.

Postal address: Colemans Hatch, Hartfield, TN7 4HG, UK

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by contacting us here.

2. What data do we collect about you, for what purpose and on what ground we process it

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

Communication Data

This includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

Customer Data

This includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

User Data

This includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

Technical Data

This includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

Marketing Data

This includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is either consent or our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

We may also use Communication Data, Customer Data, User Data, Technical Data and Marketing Data for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to establish, pursue or defend legal claims.

Sensitive Data, Criminal Conviction Data and Automated Processing

We do not ask for or require special category (sensitive) data, and we ask that you do not share it with us. Special category data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. If you choose to volunteer such data, for example in a free-text answer, a message or a conversation with us, you do so on your own initiative and you explicitly consent to us processing it. We will process it only so far as necessary to respond to you or to provide the service you have asked for, on the basis of that consent and our legitimate interests in assisting and communicating with the people who contact us, and then handle it in line with this notice. Please do not share more than you are comfortable with.

We do not collect any information about criminal convictions and offences.

Automated decision-making

We do not carry out solely automated decision-making that has a legal or similarly significant effect on you.

We may use automated processes to help us operate our business more efficiently. This means we may use systems or tools to analyse your personal data to support certain decisions and processes.

These automated processes are used for purposes such as:

scoring self-assessments and questionnaires, such as our online scorecards
tailoring the content and communications you receive from us
analysing trends or preferences
managing administrative processes

These processes do not have a legal or similarly significant effect on you. They are used to support our internal processes and to provide relevant content, and do not materially affect your rights, opportunities or access to services. Where appropriate, we apply human oversight to these processes.

3. How we collect your personal data

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this.

We may receive data from third parties such as analytics providers such as Google based outside the UK, advertising networks such as Facebook based outside the UK, search information providers such as Google based outside the UK, and providers of technical, payment and delivery services.

We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

4. Marketing communications

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations (PECR), we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

We will never share your personal details with any third party for their own marketing purposes.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by emailing or using our web form at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below:

Service providers who provide IT and system administration services and marketing services.
Professional advisers including lawyers, bankers, auditors and insurers.
Government bodies that require us to report processing activities.
Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We are subject to the provisions of the UK General Data Protection Regulation (UK GDPR) that protect your personal data. Where we transfer your data to third parties outside of the UK, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

We may transfer your personal data to countries that the United Kingdom regulatory authorities have approved as providing an adequate level of protection for personal data; or
If we use US-based providers that are part of the UK-US Data Bridge (the UK Extension to the EU-US Data Privacy Framework), we may transfer data to them, as they have equivalent safeguards in place; or
Where we use certain service providers who are established outside of the UK, we may use specific contracts approved by the ICO (the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses), or codes of conduct or certification mechanisms approved by the UK government, which give personal data the same protection it has in the UK.

If none of the above safeguards are available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

7. Data security

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

Email is not a fully secure means of communication. For this reason, we ask that you do not send private or confidential information to us by email. If you choose to do so, you do so at your own risk.

We never receive your payment card details. Payments are processed securely by our payment provider, and card and other sensitive payment information is never transmitted to or stored by us.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

8. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding the correct retention period we look at the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it and whether we can achieve those purposes by other means, and the applicable legal requirements.

Routine operational records, such as customer-service correspondence and internal task or project records, are deleted at our discretion once we consider the matter concluded and the records are no longer needed. We do not commit to a fixed deletion schedule.

Contractual, payment and financial records are kept for the period the law requires. For tax purposes the law requires us to keep basic information about our customers for six years after they stop being customers.

Where data is no longer needed for its original purpose, we may retain it in anonymised form.

9. Your legal rights

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/

If you wish to exercise any of the rights set out above, you can contact us here.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

When responding to a request to access your personal data, we are only required to carry out searches that are reasonable and proportionate in the circumstances. This means we will take into account factors such as the nature of the information sought, the context in which it is held, any difficulty involved in locating it and the potential benefit to you of receiving it.

We try to respond to all legitimate requests within one month of receiving the request (or, where applicable, of receiving the identity verification information or clarification we have asked for, as the response period is paused while we wait for that information).

Occasionally it may take us longer than one month if your request is particularly complex or you have made a number of requests, in which case we may extend the response period by up to a further two months. We will notify you within one month of receiving your request if an extension is needed and explain why.

10. How to complain

If you have a complaint about how we handle your personal data, we ask that you contact us first so that we can try to resolve it for you.

You can submit a data protection complaint to us by:

emailing us if you have our email address
contacting us via our web form here
writing to us at Colemans Hatch, Hartfield, TN7 4HG, UK

We will acknowledge your complaint within 30 days of receiving it. We will investigate your complaint without undue delay, keep you informed of our progress, and communicate the outcome to you clearly with sufficient detail for you to understand how we reached our conclusion.

If you are not satisfied with our response, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

11. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

12. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Privacy Policy