This Privacy Policy complies with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We are committed to protecting your privacy and handling your data responsibly.

Privacy Policy

Last updated: 7th June 2026

Version: 1.0

1. Introduction & Data Controller Statement

The Black Mentor UK Ltd (trading as “The Black Mentor”) (“we”, “us”, “our”) is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our website and services.

We are the data controller for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Our registered company number is available upon request.

2. Information We Collect

2.1 Personal Information You Provide

• Contact Information: Name, email address, phone number, postal address.
• Professional Information: Job title, company, industry, experience level.
• Session Information: Goals, challenges, preferences, and basic progress notes.
• Payment Information: Billing details (processed securely by third-party payment processors).
• Communication: Messages, emails, and feedback you send to us.

2.2 Information We Collect Automatically

• Website Usage: Pages visited, time spent, device information.
• Technical Data: IP address, browser type, operating system.
• Cookies: As described in our Cookie Policy.

2.3 Special Category Data

Our services focus strictly on professional mentoring, which is distinct from therapy, medical treatment, or clinical coaching. We do not intentionally request, collect, or store “special category data” (such as details regarding your health, race, ethnicity, or religious beliefs) under the UK GDPR.

We maintain only basic, written notes of our sessions to track your professional goals and progress. We kindly ask that you avoid sharing highly sensitive personal or medical attributes during our sessions or in written communications unless you deem it strictly relevant to your mentoring journey, in which case it will only be noted with your explicit consent.

3. How We Use Your Information

We process your personal data for the following purposes:

3.1 Service Provision (Legal Basis: Contract)

• Delivering mentoring services.
• Scheduling and managing appointments.
• Processing payments and managing billing.
• Communicating about your sessions and progress.

3.2 Legitimate Business Interests

• Improving our services and website functionality.
• Analysing usage patterns and preferences.
• Ensuring website security and preventing fraud.
• Managing customer relationships.

3.3 With Your Consent

• Sending marketing communications and newsletters.
• Personalizing content and recommendations.
• Using testimonials and case studies (anonymized).
• Placing non-essential cookies on your device.

3.4 Legal Obligations

• Complying with accounting and tax requirements.
• Responding to legal requests and court orders.
• Protecting our legal rights and interests.

4. Data Retention

We will retain your personal information on our systems only for as long as necessary to fulfil the purposes for which it was collected.

• Client & Mentoring Records: 7 years after the end of our professional relationship (in line with professional practice and standard legal limitation periods).
• Financial Records: 6 years after the end of the relevant accounting period (as required by HMRC).
• Marketing Data: Email addresses held for our newsletter via MailerLite are retained until you choose to unsubscribe, withdraw consent, or after 3 years of inactivity.
• Website Analytics Data: Website usage and analytics logs collected via WordPress.com are retained for a maximum of 26 months.
• Enquiries (non-clients): 2 years from last contact.

After these periods have elapsed, we will securely delete or anonymize your personal data.

5. Data Sharing and Third-Party Disclosures

We do not sell, trade, or rent your personal information. We may share your data only in the following circumstances:

5.1 Service Providers

We share data with trusted third-party service providers who assist us in operating our business and hosting our infrastructure:

• Website Platform (WordPress.com): Hosts our website platform and processes basic technical data and cookie logs.
• Newsletter Distribution (MailerLite): Manages our newsletter subscription list and dispatches updates. As a UK-billed customer, our subscriber data is handled securely on servers located within the European Union (Germany and the Netherlands).
• Payment Processors: (e.g., Stripe, PayPal) for secure payment handling.
• Scheduling & Operations: Calendar booking systems, email service providers, and video conferencing platforms used to deliver virtual sessions.

All service providers are required to comply with UK GDPR and are bound by data processing agreements that restrict their use of your personal data to the specific services they provide to us.

5.2 Legal Requirements

• When required by law or court order.
• To protect our legal rights, safety, or property.
• To prevent fraud or mitigating security vulnerabilities.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of business assets, your information may be transferred as part of that transaction. We will ensure that any such transfer complies with UK data protection law and that your rights are protected. You will be notified of any such change in ownership or control of your personal data.

6. International Data Transfers

While our core newsletter database is hosted securely within the UK/EU framework via MailerLite, our use of WordPress.com involves the transfer of basic technical data and website analytics to servers located in the United States.

To ensure your personal data receives an equivalent level of protection to that guaranteed by the UK GDPR, these transfers are strictly safeguarded. Automattic Inc. protects this data by adhering to the UK Extension to the EU-U.S. Data Privacy Framework and utilizing standard statutory data protection clauses (Standard Contractual Clauses) approved by the UK Information Commissioner’s Office (ICO).

7. Cookies and Tracking Technologies

Our website, hosted by WordPress.com, uses cookies and similar tracking technologies to ensure essential site functionality, memorize your preferences, and analyse our web traffic.

• Essential Cookies: Necessary for the technical operation and security of the website.
• Analytics and Performance Cookies: Provided via WordPress to help us understand how visitors interact with the site, allowing us to improve user experience.

You can choose to accept or decline non-essential cookies via the cookie consent banner when you first visit our website, or by adjusting your browser settings. For a full breakdown of the specific cookies we use, please refer to our dedicated Cookie Policy.

8. Children’s Privacy

Our website and mentoring services are directed exclusively at adults and are not intended for, or targeted at, individuals under the age of 18. We do not knowingly collect or solicit personal information from anyone under 18. If we discover that we have inadvertently collected personal data from a child without verifiable parental consent, we will take immediate steps to delete that information from our systems and servers.

9. Automated Decision-Making and Profiling

We do not use automated decision-making or profiling algorithms to make decisions that produce legal or similarly significant effects concerning you. All decisions regarding the delivery of our mentoring services and client onboarding are conducted via human review and direct collaboration.

10. Your Legal Rights

Under the UK GDPR, you possess specific rights regarding your personal data, which you can exercise at any time by contacting us:

• Right of Access: Request a copy of the personal data and basic session notes we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure: Request deletion of your personal data, subject to our overriding statutory financial or legal retention obligations.
• Right to Restrict or Object: Request limitation of how we use your data, or object to processing based on legitimate interests. You have an absolute right to object to direct marketing and can unsubscribe from our newsletter at any time using the link in our emails.
• Right to Data Portability: Request the transfer of your data to another service in a structured, commonly used format.
• Right to Withdraw Consent: Withdraw consent for marketing or other consent-based processing at any time.

To exercise any of these rights, please contact us using the details in Section 13. We will respond to your request within one month of receipt. In complex cases, we may extend this by a further two months, in which case we will inform you of the extension and the reasons for it. These rights are not absolute and may be subject to legal exemptions.

Whilst we take all reasonable technical and organizational steps to protect your data, no method of transmission over the internet or electronic storage is 100% secure; we cannot guarantee absolute security.

11. Data Breach Notifications

We take the security of your personal data very seriously. In the unlikely event of a data breach that compromises your personal information, we have strict procedures in place to assess and manage the incident.

• To the Regulator: Where a breach is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner’s Office (ICO) without undue delay and, where feasible, within 72 hours of becoming aware of the breach.
• To You: If the breach is likely to result in a high risk to your individual rights and freedoms, we will communicate the breach directly to you without undue delay, providing clear information on the nature of the breach and the steps you can take to mitigate any potential risks.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our professional practices, service offerings, or legal and regulatory obligations.

Any changes we make will be posted on this page, and the “Last Updated” date at the top of the document will be modified accordingly. If we make significant changes to how we handle or process your personal data, we will provide a more prominent notice prior to the change becoming effective. We encourage you to review this policy periodically to stay informed about how we protect your information.

13. Contact and Complaints

If you have any questions about this Privacy Policy or wish to exercise your legal rights, please contact our Data Controller at:

• Email: contact@blackmentoruk.com

• Postal Address: Black Mentor UK Ltd, 31 Kennedy House, 31 Stamford Road, Altrincham, Cheshire WA14 1ES

If you remain unsatisfied with how we handle your data, you have the right to lodge a complaint with the UK supervisory authority, the Information Commissioner’s Office (ICO). You can contact them via their website at www.ico.org.uk or by calling their helpline on 0303 123 1113.