Privacy policy

Last updated: 9 October, 2026

1. Introduction and who we are

This Privacy Policy explains how and why WABYA LTD ("wabya", "we", "our", "us") uses Personal Data about visitors to our websites, people who enquire about our services, our clients, and our coaches.

We are WABYA LTD, a company registered in England and Wales with company number 13373919. We are registered with the Information Commissioner's Office. We are the controller of the Personal Data described in this policy, meaning we are legally responsible for deciding how and why it is used. There is one exception, explained in section 8: your Coach may keep a limited professional record of their own and, where they determine why and how that record is kept, they act as a separate controller for that record.

This policy covers our websites at www.wabya.com and www.wearebecauseyouare.com (together, the "Site").

wabya is a coaching and consulting business. We design and deliver THE RESET™, a structured coaching programme offered in two forms: the Personal Reset for individuals, and the Leadership Reset for organisations and their leadership teams. We review every enquiry personally and match each client with a Coach.

We take your privacy seriously. Please read this policy carefully. When we use your Personal Data we are subject to the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. What this policy applies to

This policy applies to your use of our Site and our services. It is not a contract, and it is separate from our Terms of Service, which govern the coaching services you buy from us. If the two documents conflict on the subject of Personal Data, this policy applies.

Our Site links to third party sites, including our social media channels. Those third parties collect information about you under their own privacy policies, which you should read separately.

Our lawful bases

We only use Personal Data where we have a lawful basis to do so. Depending on the circumstances, we rely on:

Contract — where processing is necessary to take steps at your request before entering into a contract with you, or to perform our contract with you, including assessing your enquiry, arranging and delivering Services, communicating with you and administering payment.
Legitimate interests — where necessary to operate and improve our business, respond to business enquiries, match clients with Coaches, manage our relationships with clients, Coaches and organisations, maintain appropriate records, protect our systems and establish, exercise or defend legal rights, provided those interests are not overridden by your rights and interests.
Legal obligation — where we need to use or retain information to comply with tax, accounting, regulatory or other legal requirements.
Consent — where we specifically ask for it, including for marketing, non-essential cookies or pixels, session recordings and certain sensitive information.

Where we process special category information, we also need a separate condition under Article 9 UK GDPR. Section 6 explains this.

3. Our website

Our Site is hosted on Shopify, which processes technical information about your visit in order to serve and secure the Site.

You cannot buy anything on our Site. Our programme pages are informational. There is no customer account, no login and no checkout. If you want to work with us there are two routes: contact us directly, or complete one of our questionnaires described in section 4.

4. Our questionnaires

4.1 The Clarity Check (Personal Reset)

If you are interested in the Personal Reset we ask you to complete the Clarity Check, a short questionnaire hosted on Google Forms. It is how we decide whether we can help you and which Coach may be right for you.

The Clarity Check asks for your email address and full name, and asks about your situation: what has brought you to wabya, how clear or consistent things feel at the moment, what is getting in the way, what kind of support would help, how ready you are to act, whether you have been coached before, and your role or work context if relevant.

Several questions are free text, including one asking whether there is anything else about where you are that would help us understand what is going on. You decide what to put there. Please see section 6 before including information about your health or other sensitive matters.

One question asks whether you are exploring support for someone else. If you tell us about another person, please share only what is necessary. Section 7 explains how we handle information about people who have not contacted us themselves.

Your response is reviewed by our co-founder, Jean-François, who aims to come back to you within 48 hours with a clear next step. If we think we can help, we identify a Coach we believe is a good match and share your response with that Coach so they can consider the match and prepare. We share your full response, not a summary. If the Coach agrees the match is right, we introduce you for a discovery call. You are under no obligation at this stage. Completing the Clarity Check or having an introductory call does not itself create a contract for paid Services.

4.2 The Leadership Reset intake questionnaire

If you are exploring the Leadership Reset for your organisation we ask you to complete an intake questionnaire, also hosted on Google Forms. It asks for your full name, role and company name, your company's size and structure, what you are exploring, what currently feels off in the organisation, what is having the biggest impact, what success would look like, how ready you are to act, and what would be most useful in a first conversation. Two questions are free text.

Your response comes to the wabya team for review before we respond and arrange a call.

5. Session recordings, transcripts and AI notes

Sessions are held online. Where your Coach is one of our founders, sessions are held on Google Meet, or occasionally on another video platform by agreement. Other Coaches choose the platform they use for their own sessions, and will tell you which one at the outset.

Where wabya records a session, the recording is stored in our Google Workspace, and we may produce a transcript or written summary using Gemini within Google Workspace. Google acts as our processor for this, under contractual terms which mean your content is not used to train Google's models and is not used for advertising.

We will always tell you before we record and ask for your explicit consent. You can decline, and declining will not affect your programme or how we work with you. If you agree and later change your mind, tell us and we will stop recording future sessions and, if you ask, delete existing ones unless we need to keep them for a legal claim.

Recordings, transcripts and summaries made by wabya are treated as confidential and are not shared outside wabya and your Coach, except as described in section 10.

Separately, a Coach may keep notes for their own professional record. If a Coach wishes to record a session for their own professional record, they must tell you beforehand and obtain your explicit consent before recording. Those independent records are handled by the Coach as described in section 8.2.

6. Health and other sensitive information

Some information is given extra protection by law, including information about your physical or mental health, racial or ethnic origin, religious or philosophical beliefs, sex life or sexual orientation, genetic or biometric data, and trade union membership. The law calls this "special category" information.

wabya does not provide therapy, counselling, medical treatment or any regulated health service. We do not ask you for health information, and no question in the Clarity Check requires it.

But coaching is personal. The Clarity Check has free-text questions, and in sessions you may talk about anything you choose. People sometimes tell us about their mental health, their wellbeing or a health condition. We would rather say so plainly than pretend otherwise.

Where you give us this kind of information, we rely on:

Your explicit consent, under Article 9(2)(a) UK GDPR, to use it in order to assess whether we can help, to match you with a Coach, to share it with that Coach, and to deliver your programme. We ask for this separately and specifically, not as part of accepting this policy or our Terms of Service.
Where necessary for the establishment, exercise or defence of legal claims, under Article 9(2)(f) UK GDPR.

You can withdraw your consent at any time by emailing us. We will then stop using the relevant special category information for those purposes and delete it where we no longer have another lawful reason to retain it. We will also ask your Coach to do the same where we have shared that information with them. Withdrawing consent does not make our earlier use unlawful, but it may mean we cannot match you with a Coach or continue a programme.

Share only what you feel is relevant. You are never obliged to disclose health information, and you can raise anything sensitive with your Coach in a session rather than putting it in writing.

If you tell us something that gives us serious concern for your safety or someone else's, we may need to act on it. Our Terms of Service explain when.

7. Information about other people

Sometimes people give us information about someone else: an individual exploring support on behalf of a friend or family member, or a leader describing their team in the Leadership Reset questionnaire.

If you do this, please share only what is necessary, and avoid including information about a named person's health, personal circumstances or performance.

Where we hold information about someone who has not contacted us directly, we rely on our legitimate interests in assessing whether we can help. We keep it to a minimum, we do not use it to contact that person without a reason to, and we will provide them with this policy on request.

8. Coaches: what we hold and what your Coach holds

Our Coaches are experienced professionals certified by the International Coaching Federation (ICF), the European Mentoring & Coaching Council (EMCC), or the Association for Coaching (AC). They are engaged by wabya but also carry their own professional obligations, which means information about you sits in two places.

8.1 Information wabya controls

Your enquiry and your Clarity Check or intake questionnaire response.
Our assessment of whether we can help, and our decision about which Coach to match you with.
Your contract, invoicing and payment records, including the schedule of payments.
Correspondence between you and wabya.
Any session recording or transcript made by wabya.
Feedback, complaints and quality records.

Your Coach arranges session times directly with you. Where a Coach carries out other activities on our behalf, such as confirming attendance to us, they act on our instructions and we remain responsible.

8.2 Information your Coach holds independently

A Coach may keep a limited professional record of their work with you for their own professional, ethical, accreditation, insurance or legal purposes. Where the Coach determines for themselves why and how that record is kept, rather than acting on wabya's instructions, the Coach acts as a separate controller in relation to that record.

That record may include the Coach's own notes and, if you have explicitly consented in advance, a recording of a session. It is confidential and is not routinely shared with wabya.

The Coach is responsible for complying with applicable data protection law in relation to that independent record, including providing appropriate privacy information, keeping the information secure, deciding how long it is retained and responding to requests concerning your data protection rights.

To find out what your Coach holds, or to exercise your rights in relation to their independent record, you can contact your Coach directly. If you would rather not, contact us using the details in section 15 and we will help route your request.

9. Marketing

We will only send you marketing emails where you have given consent, or where you are an existing or former client and we are telling you about our own similar services. Either way you can opt out at any time, using the unsubscribe link in any marketing email or by emailing us.

Opting out does not stop messages we need to send about your programme, bookings or changes to our terms.

We do not sell your Personal Data and we do not share it with third parties for their own marketing.

10. Who we share your Personal Data with

We share Personal Data where relevant with:

Your Coach, or a proposed Coach, as described in sections 4 and 8.
Shopify, which hosts our Site.
Google, whose Workspace services we use for email, for the Google Forms hosting our questionnaires, for storing files, for holding video sessions on Google Meet, and for producing transcripts and summaries using Gemini.
Stripe and GoCardless, which process payments.
FreeAgent, which we use for invoicing and accounting.
Meta, in connection with the advertising pixel on our Site, where you have consented. See section 12.

We also share Personal Data, where necessary, with our professional advisers including lawyers and accountants; with law enforcement, courts and regulators where legally required; and with a party that acquires or may acquire our business, in which case we anonymise where we can and the recipient is bound by confidentiality.

11. How long we keep your Personal Data

We keep Personal Data only as long as we need it. Our periods are:

Clarity Check and intake questionnaire responses where you do not go on to work with us: 12 months from the date of your response.
Enquiries that do not lead to a programme: 12 months.
Client records, including programme and session records: 6 years after your programme ends, reflecting the period in which a claim could be brought.
Session recordings and transcripts made by wabya: 6 months after your programme ends, unless you ask us to delete them sooner.
Financial and transaction records: 6 years after the end of the accounting period they relate to, as required by tax law.
Marketing preferences: until you opt out, then a minimal record that you have opted out.
Records about our Coaches, including their contract, identity documents and engagement history: 6 years after the engagement ends.

When we no longer need Personal Data we delete or anonymise it. The periods above apply to records wabya holds. Your Coach's own professional record about you is separate, and they decide how long to keep it, as explained in section 8.2.

12. Cookies and the Meta pixel

Cookies are small files placed on your device when you visit a website. Our Site uses cookies that are strictly necessary for it to work and stay secure. These are set by Shopify and do not require your consent.

Our Site also carries a Meta advertising pixel, which allows us to measure the performance of our advertising and to reach people on Meta's platforms. This is not strictly necessary, so we will only run it where you have given consent, and you can change or withdraw that consent at any time. For this activity, we and Meta each have responsibilities for your information.

Most browsers let you block or delete cookies through their settings, although blocking strictly necessary cookies may stop parts of the Site working.

13. Your rights

You have the following rights, which you can normally exercise free of charge. They do not all apply in every situation.

Access — to be given a copy of the Personal Data we hold about you.
Correction — to have inaccurate Personal Data corrected.
Erasure — to have your Personal Data deleted, in certain situations.
Restriction — to have us limit our use of your Personal Data, in certain situations.
Portability — to receive Personal Data you gave us in a structured, commonly used, machine-readable format, and to have it sent elsewhere, in certain situations.
Objection — to object at any time to direct marketing, and in certain other situations to our continued use of your Personal Data.
Withdrawal of consent — where we rely on consent, to withdraw it at any time. This does not affect our use of the information beforehand.
Not to be subject to a decision based solely on automated processing. We do not make such decisions; every enquiry is read and assessed by a person.

To exercise a right, contact us using the details in section 15. Tell us which right you want to exercise and what it relates to. We may need to verify your identity. We will respond within one month and will tell you if we need longer.

If your request concerns your Coach's own professional record, see section 8.

14. How to complain

If you have a concern about how we have used your Personal Data, please contact us first using the details in section 15 and we will try to resolve it.

You also have the right to complain to the Information Commissioner's Office at https://ico.org.uk/make-a-complaint or by telephone on 0303 123 1113.

15. How to contact us

For any question about this policy, to exercise a right, or to make a complaint, email youare@wabya.com

By post: WABYA LTD, 6 Chelsham Road, London, SW4 6NP.

For the purposes of data protection law, WABYA LTD is the controller of your Personal Data, except for your Coach's own professional record described in section 8.

16. Children

Our services are for adults. They are not intended for anyone under 18 and we do not knowingly collect Personal Data about children. If you believe a child has given us their Personal Data, contact us and we will delete it.

17. Transferring your Personal Data outside the UK

Some of our suppliers are based outside the UK or store or access data outside it. Where we transfer your Personal Data outside the UK we do so only where the law allows: because the UK Government has decided the country provides adequate protection, because appropriate safeguards are in place (normally the UK International Data Transfer Agreement or the UK Addendum to the European Commission's Standard Contractual Clauses), or because a specific exception applies.

18. Changes to this policy

We may update this policy to reflect changes in how we work or in the law. We will post the updated version on our Site and change the date at the top. Where changes are material we will take reasonable steps to bring them to your attention.