Legal
Privacy Policy
This policy explains what personal data FluentISH collects, why, how it is used, and what rights you have under UK data protection law.
Last updated: 30 April 2026
1. Who we are
FluentISH is a sole trader business providing bespoke 1-on-1 conversational French coaching. The data controller for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 is:
Bolton
BL6 7JY
United Kingdom
bonjour@fluentish.co.uk
FluentISH is a sole trader. We have assessed our data protection obligations and comply with the requirements of the UK GDPR and the Data Protection Act 2018.
2. What personal data we collect
Depending on how you interact with FluentISH, we may collect the following:
- Identity data: first name, last name
- Contact data: email address, phone number
- Communications data: the content of messages sent via email, WhatsApp or SMS
- Booking data: your preferred session times and scheduling history
- Payment data: transaction records. Card details are processed directly by Stripe and are never seen or stored by FluentISH.
- Marketing response data: whether you submitted an enquiry form via a Meta (Facebook or Instagram) advertisement
- Session notes: brief notes kept internally to track your progress and tailor sessions to your goals
We do not collect any special category data (such as health, religion or ethnicity) and we ask that you do not send us any.
3. How we collect your data
- Directly from you when you complete an enquiry or lead form via a Meta advertisement
- When you book a session through our booking system (Calendly or equivalent)
- When you contact us by email, WhatsApp or SMS
- When you make a payment via Stripe
- Through ongoing session notes created by Dan Blumenau
4. Why we use your data and our lawful basis
UK GDPR requires us to have a lawful basis for every use of your personal data. The table below sets out our purposes and the basis we rely on for each.
| Purpose | Lawful basis |
|---|---|
| Responding to an enquiry submitted via a Meta lead advertisement | Consent (Article 6(1)(a)). You provided your details and consented to being contacted when you submitted the form. |
| Arranging and managing your coaching sessions | Performance of a contract (Article 6(1)(b)). Processing is necessary to deliver the service you have engaged. |
| Processing payment for sessions | Performance of a contract (Article 6(1)(b)). |
| Maintaining financial records for tax and accounting purposes | Legal obligation (Article 6(1)(c)). HMRC requires retention of business records for at least six years. |
| Communicating with you about sessions via email, WhatsApp or SMS | Legitimate interests (Article 6(1)(f)). Session coordination is a reasonable expectation of the coaching relationship. |
| Keeping internal session notes to personalise coaching | Legitimate interests (Article 6(1)(f)). Tailoring sessions to your progress is central to the service provided. |
| Contacting existing clients about related services or session availability | Legitimate interests (Article 6(1)(f)), subject to your right to object at any time. |
Where we rely on legitimate interests, we have assessed that those interests do not override your rights and freedoms, given the nature and limited scale of the data involved and the reasonable expectations created by the coaching relationship.
Where we rely on consent, you have the right to withdraw it at any time by contacting us at bonjour@fluentish.co.uk. Withdrawal of consent does not affect the lawfulness of processing that took place before withdrawal.
5. Electronic marketing and PECR
The Privacy and Electronic Communications Regulations 2003 (PECR) apply to marketing messages sent by email, SMS and similar electronic means.
We will only contact you by SMS or WhatsApp for marketing purposes if you have given us explicit consent to do so, typically by submitting a Meta lead advertisement form that clearly states you will be contacted in this way.
We may contact existing clients about our coaching services by email or SMS under the soft opt-in rule, where those clients have previously engaged our services and we are contacting them about the same or similar services. You may opt out of such communications at any time by replying STOP to any SMS, or by emailing bonjour@fluentish.co.uk.
6. Who we share your data with
We do not sell your personal data. We share it only with the following third-party service providers who process data on our behalf or alongside us as separate controllers, and only to the extent necessary to provide the service:
| Provider | Purpose | Role |
|---|---|---|
| Stripe, Inc. | Payment processing | Processor |
| Meta Platforms, Inc. | Advertising, lead form collection | Independent controller |
| Google LLC | Client record management (Google Sheets) and website fonts | Processor |
| Zoho Corporation Pvt. Ltd | Email communications | Processor |
| Calendly LLC (or equivalent booking tool) | Session scheduling and booking | Processor |
| WhatsApp LLC (a Meta company) | Session communication | Independent controller |
Where these providers act as processors, we have ensured (or will ensure) that appropriate data processing agreements are in place. Where they act as independent controllers (Meta, WhatsApp), their own privacy policies govern how they process your data in connection with their platforms.
We may also disclose your data where required to do so by law, court order, or a regulatory authority.
7. International data transfers
Several of our service providers are based or process data outside the United Kingdom. When your data is transferred internationally, we ensure appropriate safeguards are in place, which may include:
- Transfers to countries with a UK adequacy decision
- Standard contractual clauses (SCCs) or International Data Transfer Agreements (IDTAs) approved for use under UK law
- Binding corporate rules or other mechanisms recognised under UK GDPR
You may request further information about the specific safeguards in place for any transfer by contacting us at bonjour@fluentish.co.uk.
8. How long we keep your data
| Data type | Retention period | Reason |
|---|---|---|
| Enquiry leads (not converted to clients) | 12 months from last contact | Reasonable follow-up window; then deleted |
| Client contact and session records | Duration of the coaching relationship, plus 6 years | Limitation period for contract claims under the Limitation Act 1980 |
| Payment and financial records | 7 years from the end of the relevant financial year | HMRC requirement |
| WhatsApp and SMS communications | Duration of the coaching relationship | Session coordination; deleted on conclusion of relationship |
| Session notes | Duration of the coaching relationship, plus 1 year | Continuity of service; then deleted |
After the applicable retention period has passed, your data is securely deleted or anonymised so that it can no longer be attributed to you.
9. Your rights
Under UK GDPR you have the following rights in relation to your personal data. To exercise any of them, contact us at bonjour@fluentish.co.uk. We will respond within one month.
- Right of access. You may request a copy of the personal data we hold about you (a Subject Access Request).
- Right to rectification. You may ask us to correct inaccurate or incomplete data.
- Right to erasure. You may ask us to delete your data where there is no legitimate reason for us to continue holding it.
- Right to restrict processing. You may ask us to pause processing your data while a concern is resolved.
- Right to data portability. Where processing is based on consent or contract and is carried out by automated means, you may request your data in a structured, commonly used, machine-readable format.
- Right to object. You may object to processing based on legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
- Right to withdraw consent. Where processing is based on consent, you may withdraw it at any time without affecting processing that took place beforehand.
- Rights related to automated decision-making. We do not make any decisions about you solely by automated means that produce legal or similarly significant effects.
These rights are not absolute and exemptions may apply. We will explain the position clearly if we are unable to comply with a request.
10. Cookies and website technologies
This website uses the following third-party services that may make network requests when you visit:
- Google Fonts (fonts.googleapis.com, fonts.gstatic.com): loads typefaces used on the site. Google's servers receive your IP address as part of this request. No cookie is set by FluentISH in connection with this service.
- Tailwind CSS CDN (cdn.tailwindcss.com): loads the site's styling library. Again, your IP address is transmitted to the CDN provider.
This website does not set first-party cookies and does not use any analytics, tracking or advertising scripts. If a booking tool (such as Calendly) is embedded on this site, that tool may set its own cookies subject to its own privacy policy.
11. Changes to this policy
We may update this policy from time to time. The date at the top of the page will always reflect when it was last revised. Where changes are material, we will take reasonable steps to bring them to your attention.
12. Complaints
If you believe we have not handled your data correctly, please contact us first at bonjour@fluentish.co.uk and we will do our best to resolve the matter.
You also have the right to lodge a complaint with the UK's supervisory authority, the Information Commissioner's Office (ICO):
ico.org.uk
Telephone: 0303 123 1113