Last Updated: August 2026 | Document Version: 1.01

At Ellington Shaw Corporate Partners Ltd ("we," "our," or "us"), we are committed to protecting your privacy and maintaining the highest standards of data confidentiality. This Privacy Policy explains how we collect, use, and safeguard personal information when you visit our website, contact us, or engage our executive coaching services.

1. Who We Are

Ellington Shaw Corporate Partners Ltd is an executive presentation, communication, and public speaking coaching firm based in London, UK.

• Company Registration Number: 17367277

• Data Protection Contact: support@ellingtonshaw.com

• Data Protection Authority Registration: ICO Registration ZC227674

  
  

2. Our Core Principle: Zero Content Retention Model

We operate under a strict Zero Content Retention approach for all coaching services:

• No Recording or Storage: We do not record, transcribe, cache, or store any live presentation materials, screen shares, video feeds, or spoken content shared during coaching sessions.

• Transient Real-Time Processing: Session content exists exclusively in temporary volatile memory (RAM) during live streaming calls and is purged immediately upon disconnection.

• No AI Training: Client presentation materials and session communications are never used to train internal or third-party artificial intelligence (AI) or machine learning models.

  
  

3. Personal Data We Collect

While we do not hold presentation content, we collect operational personal data necessary to run our business:

• Contact Information: Name, job title, corporate email address, and phone number when you submit an inquiry form or book a session.

• Transaction & Billing Data: Invoicing details, VAT/tax numbers, and payment records (processed securely via third-party payment gateways).

• Technical & Website Usage Data: IP addresses, browser types, and standard analytics metadata when navigating our website.

  
  

4. How We Use Your Data & Lawful Basis

We process your personal data under the following legal bases:

• Contractual Necessity: To deliver scheduled coaching sessions, issue invoices, and manage client communications.

• Legitimate Interests: To maintain proper business accounting, protect our IT systems against cyber threats, and respond to commercial inquiries.

• Consent: Where you explicitly agree to receive marketing communications or non-essential website cookies.

  
  

5. Automated Decision-Making & Profiling

We do not carry out any automated decision-making or profiling on your personal data. All client evaluations and interactions are conducted entirely by human executive coaches.

6. Data Sharing & Third-Party Vendors

We never sell, rent, or trade your personal data. Operational data is shared only with trusted third-party subprocessors strictly required to deliver our service:

• Video Conferencing: (e.g., Zoom / Microsoft Teams) — Configured with cloud recording and AI summarization features permanently disabled.

• Business Operations: (e.g., Google Workspace / Microsoft 365) — For email and calendar scheduling.

• Invoicing & Accounting: (e.g., Xero / Stripe) — For payment processing and accounting compliance.

  
  

7. International Data Transfers

Where operational data is transferred outside the UK or European Economic Area (EEA), we ensure appropriate safeguards are in place. This includes utilizing Standard Contractual Clauses (SCCs) or verifying certification under the UK Extension to the EU-US Data Privacy Framework.

8. Data Security Measures

We employ robust technical and organizational measures to prevent unauthorized access, disclosure, or alteration of operational data:

• End-to-end encryption for video conferencing streams.

• Hardware-level encryption and Multi-Factor Authentication (MFA) across all team devices.

• Strict "Clean Room" protocols ensuring coaches conduct live sessions in secure, private environments.

  
  

9. Data Retention

• Operational & Financial Data: Retained for as long as necessary to fulfill contractual obligations and statutory financial retention laws (typically 6–7 years for accounting records).

• Inquiry Data: Deleted 12 months after the last communication if an engagement does not proceed.

• Session Content: Purged instantly upon completion of the live coaching call.

  
  

10. Your Legal Rights

Depending on your location (under UK GDPR, EU GDPR, or CCPA), you have the right to request access, correction, or erasure of your operational data. To exercise these rights, contact support@ellingtonshaw.com.