1. Who we are

Keys to Impact is a trading name of Product Innovation Consulting Ltd, registered in England & Wales (Company No. 15815378). Our registered office is 20-22 Venture West Greenham Business Park, Newbury, England, RG19 6HX. 

We are the data controller of your personal data under the UK General Data Protection Regulation (UK GDPR) and other applicable laws.

 

2. What this policy covers

This Privacy Policy explains:

• What personal data we collect and why
  
• How we use and share it
  
• Your privacy rights and choices
  
• How to contact us about privacy matters

 

3. What is personal data?

“Personal data” means any information that identifies you or could be used to identify you.

This may include:

• Contact details – name, email address, phone number, postal address
• Payment details – billing address, transaction history (we do not store full card details)
• Professional information – job title, company name
• Programme participation data – course enrolments, progress, coaching notes
  Special category data – if you share information on gender identity, ethnicity, health, or other sensitive matters (collected only with your explicit consent)
• Technical data – IP address, browser type, device identifiers, cookies 

 

4. How we collect your data

We collect personal data when you:

• Sign up for a course or challenge via Kajabi
• Subscribe to our newsletter via Substack
• Join our free email course via Kit/ConvertKit
• Join our private Slack community
• Attend coaching or training sessions via Google Meet (online) or in person
• Share documents, feedback, or resources with us via Google Workspace (e.g., Google Docs, Sheets, Drive)
• Take part in surveys, research, or evaluations
• Contact us by email, phone, or social media
• Use our website (cookies and analytics tools may collect usage data)

 

5. How we use your data

We use your data to:

• Deliver and administer our courses, challenges, and coaching
• Process payments and manage accounts
• Communicate with you about services you’ve purchased
• Send newsletters or marketing (if you’ve opted in)
• Run research and analyse participation data to improve services
• Comply with legal requirements and protect our business

 

6. Lawful bases for processing

We process your personal data under one or more of these bases:

• Contract – to deliver services you’ve purchased
• Consent – for marketing emails and special category data
• Legitimate interests – to improve services, maintain security, and prevent fraud
• Legal obligation – to comply with applicable laws

 

7. Special category data

If you share sensitive information (e.g., health, identity, diversity data), we collect and process it only with your explicit consent, store it securely, and use it only for the stated purpose.

 

8. Sharing your data

We only share your personal data with trusted service providers who help us operate our business, including:

• Kajabi – course delivery
• Substack – newsletters
• ConvertKit/Kit – email courses and marketing
• Google Workspace & Google Meet – for email, file storage, calendar scheduling, document collaboration, and online video sessions (data may be stored in the US or other countries with GDPR safeguards such as Standard Contractual Clauses)
• Slack – for community interaction
• Stripe, PayPal – payment processing
• Google Analytics – website analytics
  

These providers may store data in the UK, EEA, or US. Where data is transferred outside the UK/EEA, we use safeguards such as Standard Contractual Clauses.

 

9. Social media

If you engage with us via platforms such as LinkedIn or Instagram, those platforms process your data under their own privacy policies.

10. Cookies & analytics

We use cookies to:

• Enable site functionality
• Analyse traffic (Google Analytics)
• Improve our marketing (Facebook Pixel, where used)

You can manage cookies through our cookie banner or browser settings. Disabling cookies may affect site functionality. See our [Cookies Policy] for details.

 

11. International data rights

If you are in the UK or EU, you have rights under the UK/EU GDPR, including:

• Access to your data
• Correction of inaccurate data
• Deletion of your data (“right to be forgotten”)
• Restriction of processing
• Data portability
• Objection to processing (including marketing)

If you are a California resident, you may have rights under the CCPA, including:

• Access to data we hold about you
• Deletion of your data (subject to exceptions)
• Opt-out of sale of personal information (we do not sell personal information)

To exercise your rights, contact us at [email protected].

 

12. Data retention

We keep personal data only as long as needed for the purposes stated above, or to comply with legal requirements. After this period, data is securely deleted or anonymised.

 

13. Data security

We take appropriate measures to secure your data, including encryption, password protection, and access controls.

 

14. Data breach procedure

If a data breach occurs that risks your rights or freedoms, we will:

• Notify the ICO within 72 hours (where required)
• Inform affected individuals without undue delay
  
  

15. Your rights & complaints

You can contact us to:

• Request access to your data
• Correct or delete data
• Withdraw consent for marketing
• Make a complaint about our data handling
  
  

Contact: Christina Brugger
Email: [email protected]
Post: 20‑22 Venture West, Greenham Business Park, Newbury, RG19 6HX, UK

If we can’t resolve your concern, you can contact the UK Information Commissioner’s Office at www.ico.org.uk.

 

16. Changes to this policy

We may update this Privacy Policy from time to time. Changes will be posted on our website with the “Last updated” date.