Effective Date: 25th April 2026

Business Name: Elevure

Operated by: Ming Jun Kok

Contact Email: [email protected]

Jurisdiction: United Kingdom

1. Introduction

This Privacy Policy explains how Elevure (“we”, “us”, “our”) collects, uses, stores, shares, and protects your

personal data when you engage with our services. It applies to coaching clients, course participants, digital

product users, and community members, regardless of how our services are accessed — whether through email,

website, third-party platforms, or direct messaging.

By engaging with Elevure services in any way, you consent to the collection and use of your information as

described in this Privacy Policy.

2. Scope of This Policy

This policy applies to all personal data processed by Elevure in connection with:

One-to-one or group coaching services

Online courses, digital products, and recorded trainings (e.g. Skool)

Community engagement and communications

Messaging-based support (e.g. WhatsApp, Instagram, email)

Session scheduling, payments, and client records

Public-facing content that references anonymised client insights

This Privacy Policy is issued in accordance with the UK General Data Protection Regulation (UK GDPR) and

applicable UK privacy laws.

3. What Personal Data We Collect

We collect and process the following types of personal data, voluntarily provided by you or generated through

your engagement with our services:

a) Identity and Contact Information

Full name

Email address

Phone number or messaging handle (WhatsApp, Instagram, etc.)

Social media or username (if relevant)

b) Coaching and Intake Information

Intake form responses

Personal goals, challenges, and preferences

Coaching notes and session records

Session scheduling data and history

c) Communications and Engagement

Email correspondence

Direct messages via Instagram, WhatsApp, or other platforms

Comments in community groups or learning environments

Feedback or testimonials provided

d) Session Recordings

Audio and/or video recordings of coaching sessions (1:1 or group)

Transcripts or summaries generated from those recordings

e) Transaction and Payment Information

Purchase records

Invoicing details

Payment confirmation (processed through Stripe, PayPal, GoCardless, or other third-party platforms)

We do not store full card or banking information; this is securely handled by external processors.

f) Technical and Usage Data

Login and course access logs

Device type, browser, and usage data (from course platforms or digital product hosts)

Interactions with recorded content or replays (where available)

4. How We Use Your Data

We use your personal data for the following purposes:

a) Service Delivery and Administration

Scheduling, managing, and delivering coaching sessions

Providing access to digital products or online courses

Tracking client progress and notes for continuity

Managing communication and support

b) Content and Marketing (Anonymised)

Creating educational or promotional content using anonymised client insights

Referencing client experiences (without identification) in case studies, training content, or public-facing

posts

If explicit consent is given (verbally or in writing), content may include identifying information

c) Internal Business Operations

Record-keeping and client relationship management

Financial accounting and compliance

Monitoring service quality and improving delivery

d) Legal and Regulatory Compliance

Responding to legal requests or obligations

Complying with UK financial and data protection laws

We process your personal data only where we have a lawful basis to do so, including contractual necessity,

legitimate interests, consent (where applicable), and legal obligation.

5. Session Recording and Use

Coaching sessions may be audio and/or video recorded for:

Playback access for clients (if provided)

Internal review, training, or service improvement

Creation of anonymised insights for marketing or education

By participating in Elevure services, you consent to the recording of sessions and the use of content derived

from them under the conditions set forth in this Privacy Policy and our Terms & Conditions.

6. Use of Coaching Insights in Content

By working with Elevure, you agree that insights, breakthroughs, or language shared during your sessions may be

used in anonymised form in public-facing content.

This includes (but is not limited to):

Social media content

Podcasts or interviews

Case studies

Coaching curriculum or email newsletters

Community conversations

You will not be identified unless you provide explicit consent, which may be:

Verbal consent during a recorded session, or

Written consent (email, message, or signed release)

If you do not give this consent, any content derived from your sessions will be fully anonymised and stripped of

personal or business identifiers.

7. Lawful Basis for Processing

We rely on the following lawful bases under UK GDPR for processing your data:

Contractual necessity – to provide services you have requested or purchased

Legitimate interests – to operate, grow, and protect the business

Consent – where required, such as for marketing or identifying use of content

Legal obligation – for compliance with UK law and tax regulation

You have the right to withdraw consent where applicable by contacting [email protected].

8. Data Sharing and Third-Party Services

We use third-party tools and platforms to deliver services and store data securely. Your data may be processed

by:

Payment processors (Stripe, PayPal, GoCardless, among others)

Scheduling tools (e.g. Calendly, Google Calendar)

Coaching platforms (e.g. Zoom, Google Meet, Skool, Notion)

Email providers and communication tools (e.g. Gmail, WhatsApp, Instagram DMs)

Cloud-based storage services (e.g. Google Drive)

Analytics or CRM systems used for business optimisation

These providers are selected based on trust, compliance, and data security practices. We take reasonable steps

to ensure your data is handled securely and in accordance with UK data protection law.

We do not sell, rent, or trade your personal data to any third parties.

9. International Data Transfers

Some tools we use may process data outside the UK or the European Economic Area (EEA), particularly in the

United States.

Where this occurs, we ensure appropriate safeguards are in place — such as Standard Contractual Clauses or

data processing agreements — to maintain adequate levels of protection.

10. Data Retention

Your personal data will be retained only as long as necessary for the purposes outlined in this policy, including:

Completion of coaching or course delivery

Financial record-keeping and compliance (typically up to 7 years)

Development of anonymised educational materials

Ongoing client communication, unless otherwise requested

Session recordings and notes may be retained indefinitely unless deletion is requested and it does not conflict

with legal or legitimate business needs.

11. Your Data Rights

Under the UK GDPR, you have the right to:

Request access to your personal data

Request correction of inaccurate or incomplete data

Request deletion (“right to be forgotten”) where appropriate

Request restriction or objection to certain forms of processing

Request a copy of your data in a portable format

Withdraw consent (where applicable)

To exercise these rights, please contact [email protected]. We will respond within 30 days, in accordance with

applicable laws.

12. Client Responsibility and Assumed Consent

By accessing Elevure services, you confirm that:

You meet all eligibility requirements

You have legal capacity to consent to the processing of your data

You are providing truthful, accurate information

You accept full responsibility for your use of the services

We operate under the assumption that users comply with these terms. Elevure is not responsible for false

declarations or unauthorised data provision by clients.

13. Children’s Data

Elevure services are intended for adults aged 18 and over.

By using Elevure services, you confirm that you are at least 18 years of age or that you have full legal capacity

and/or the appropriate permissions to proceed. No parental consent will be requested or required. The

responsibility lies with the user to ensure eligibility.

Elevure does not knowingly collect personal data from individuals under 18. If such data is discovered, it will be

deleted as appropriate.

14. Data Security

We implement reasonable technical and organisational measures to protect your personal data from loss,

misuse, unauthorised access, disclosure, or alteration.

While no system is completely secure, we take all reasonable steps to safeguard your information through

secure platforms and limited access.

15. Changes to This Privacy Policy

We may update this policy to reflect changes in law, business practices, or service offerings. Updated versions

will be posted on our website with a new "Effective Date."

Your continued use of Elevure services constitutes acceptance of the revised policy.

16. Contact

For questions, data requests, or complaints regarding this Privacy Policy:

📧 [email protected]

Business Operator: Ming Jun Kok

Website: elevure.co.uk

elevure.co.uk | Elevure