Privacy policy

Last updated: May 2026

1. Who We Are

Exhale Coaching is operated by Clare Foley, a sole trader based in Kilnaboy, Co. Clare, Ireland.

For the purposes of the General Data Protection Regulation (GDPR) and the Data Protection Acts 1988–2018, Clare Foley trading as Exhale Coaching is the Data Controller in respect of your personal data.

If you have any questions about how we handle your personal data, please contact us at clare@exhalecoaching.co


2. What Data We Collect

We collect the following categories of personal data:


Contact and booking information:

  • Name

  • Email address

  • Phone number

  • Payment information (processed securely by Shopify Payments — we do not store card details)


Coaching intake information:

  • Information about any ADHD diagnosis or neurodiversity, where you choose to share this

  • Relevant health background, where you choose to share this

  • Personal goals and areas you wish to work on


Session information:

  • Session notes and records of your coaching engagement

  • Any materials, worksheets, or resources shared during sessions


Website and communications:

  • Email address if you subscribe to our newsletter or mailing list

  • Technical data collected automatically by Shopify to operate the website (see Section 7)


3. Special Category Data

Information about your health, ADHD diagnosis, or neurodiversity is considered special category data under GDPR and is given the highest level of protection.

We collect this information only where you choose to share it with us, and only to the extent necessary to provide you with an appropriate and informed coaching service.

We will never share this information with any third party without your explicit consent, except where required by law.


4. Why We Collect Your Data and Our Lawful Basis

We process your personal data on the following legal bases:


Contract performance:

We process your contact details, booking information, and payment details in order to fulfil our contract with you — that is, to confirm your booking, deliver your sessions, and manage your account.


Explicit consent:

We process special category data — including information about your ADHD diagnosis, neurodiversity, and health background — on the basis of your explicit consent. You provide this through our intake form prior to your first session. You may withdraw this consent at any time by contacting us, though this may affect our ability to provide a fully informed coaching service.


Legitimate interests:

We process your contact details to send you follow-up emails, check-ins, and relevant resources as an existing client. We do this on the basis of our legitimate interest in supporting your coaching journey and maintaining our client relationship. You can opt out of these communications at any time.


Legal obligation:

We retain financial records including payment information for 7 years in accordance with our obligations to Revenue Ireland.


5. How We Store Your Data

Your data is stored using the following services:


Shopify:

Your booking, contact, and payment information is stored on Shopify's platform. Shopify is GDPR compliant and processes data in accordance with their Data Processing Agreement. Shopify's privacy policy is available at shopify.com/legal/privacy.


Google Workspace:

Your intake form responses and session notes are stored in Google Workspace (Google Forms and Google Docs). Google Workspace is GDPR compliant and we have accepted Google's Data Processing Amendment. Data is stored within the European Economic Area. Google's privacy policy is available at policies.google.com/privacy.


Google Meet:

Sessions are delivered via Google Meet. Google Meet does not record sessions unless recording is explicitly enabled. Google's privacy policy is available at policies.google.com/privacy.


We do not use any other third party tools to store or process your personal data without informing you.


6. How Long We Keep Your Data

We retain your personal data for the following periods:

  • Session notes and coaching records — 7 years from the end of your coaching engagement

  • Health and special category data — 7 years from the end of your coaching engagement

  • Financial and payment records — 7 years from the date of transaction, as required by Revenue Ireland

  • Marketing and newsletter data — for as long as you remain subscribed, and deleted promptly upon unsubscribe


After the relevant retention period, your data will be securely deleted.


7. Cookies and Website Data

Our website is hosted by Shopify, which uses essential cookies to operate the website and process transactions. These cookies are necessary for the website to function and cannot be switched off.

We do not use any tracking, advertising, or analytics cookies. We do not use Google Analytics, Meta Pixel, or any similar tools.

For more information about Shopify's use of cookies, please see Shopify's privacy policy at shopify.com/legal/privacy.


8. Marketing Communications

If you are an existing client, we may send you follow-up emails, check-ins, and relevant resources on the basis of our legitimate interest in supporting your coaching journey.

You can opt out of these communications at any time by:

  • Clicking the unsubscribe link in any email

  • Contacting us directly at coachingbyclare@gmail.com


We will never send you unsolicited marketing emails without a legitimate basis for doing so, and we will never share your email address with third parties for marketing purposes.


9. Sharing Your Data

We do not sell, rent, or share your personal data with third parties for their own purposes.

We share your data only with the following service providers, strictly to the extent necessary to provide our Services:

  • Shopify — to operate our website and process bookings and payments

  • Google Workspace — to deliver and manage our coaching services


Both of these providers are bound by GDPR-compliant Data Processing Agreements.

We may share your data if required to do so by law or by a court order. We will notify you of any such request unless prohibited by law from doing so.


10. Your Rights

Under GDPR and the Data Protection Acts 1988–2018, you have the following rights in relation to your personal data:


Right of access:

You have the right to request a copy of the personal data we hold about you.


Right to rectification:

You have the right to ask us to correct any inaccurate or incomplete personal data we hold about you.


Right to erasure:

You have the right to ask us to delete your personal data in certain circumstances. Please note that we may need to retain certain data to comply with our legal obligations.


Right to restriction:

You have the right to ask us to restrict the processing of your personal data in certain circumstances.


Right to data portability:

You have the right to receive your personal data in a structured, commonly used format.


Right to object:

You have the right to object to processing based on legitimate interests, including marketing communications.


Right to withdraw consent:

Where we process your data on the basis of consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.


To exercise any of these rights, please contact us at coachingbyclare@gmail.com. We will respond within one month of receiving your request.


11. Children's Data

Our Services are intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18. If you believe we have inadvertently collected data from a minor, please contact us immediately at coachingbyclare@gmail.com and we will delete it promptly.


12. Data Security

We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, loss, or destruction.

These measures include:

  • Use of Google Workspace for storage, which provides enterprise-grade security and encryption

  • Shopify's secure payment processing — we never store payment card details

  • Password protection and access controls on all accounts holding personal data

  • Limiting access to your data to Clare Foley only


In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Data Protection Commission within 72 hours and you as soon as reasonably practicable.


13. International Transfers

Your data is stored and processed within the European Economic Area (EEA). We do not transfer your personal data outside the EEA.

Google Workspace data is stored in EEA data centres in accordance with our data region settings.


14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated policy on our website and, where appropriate, by email.

The current version of this policy will always be available on this page. The date at the top of this policy indicates when it was last updated.


15. How to Complain

If you have any concerns about how we handle your personal data, please contact us in the first instance at coachingbyclare@gmail.com and we will do our best to resolve the matter.

If you are not satisfied with our response, you have the right to lodge a complaint with the Data Protection Commission (DPC), the supervisory authority for data protection in Ireland.


Data Protection Commission

21 Fitzwilliam Square South
Dublin 2, D02 RD28
Ireland

Phone: +353 (0)1 765 0100
Website: dataprotection.ie
Email: info@dataprotection.ie