PRIVACY NOTICE
Truth Code Coaching and Consulting Ltd
Last updated
6 September 2026
Your Privacy Matters
Truth Code Coaching and Consulting Ltd is committed to handling personal information responsibly, transparently and in accordance with applicable data-protection law.
This Privacy Notice explains:
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what personal information we may collect;
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why we use it;
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the lawful bases on which we rely;
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how information may be shared;
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how long it may be retained;
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how cookies and other storage-and-access technologies are handled;
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your data-protection rights;
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how to contact us about your information.
This Notice applies to personal information processed through:
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this website;
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enquiries;
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bookings;
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applications;
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coaching and formation services;
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organisational engagements;
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workshops and events;
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communications;
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payments and administration;
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other related interactions with Truth Code Coaching and Consulting Ltd.
Who We Are
Truth Code Coaching and Consulting Ltd provides leadership resilience coaching, psychoeducation, embodied formation and organisational resilience services.
For the purposes of UK data-protection law, Truth Code Coaching and Consulting Ltd is responsible for determining how and why personal information is processed in connection with its services.
Contact:
Truth Code Coaching and Consulting Ltd
124 City Road
London
EC1V 2NX
United Kingdom
Email: info@obiokolo.com
The Information We May Collect
The personal information we process depends on how you interact with us.
It may include:
Identity and contact information
For example:
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name;
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email address;
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telephone number;
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organisation;
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job title or professional role;
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correspondence details.
Enquiry and booking information
For example:
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the service you are interested in;
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information submitted through enquiry or booking forms;
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appointment details;
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relevant organisational context.
Service and engagement information
Where you become a client or participant, this may include information you choose to provide about:
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leadership situations;
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professional responsibilities;
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goals;
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challenges;
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reflection and practice;
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communications relating to the engagement.
We aim to collect only information reasonably relevant to the service being provided.
Payment and transaction information
This may include:
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payment status;
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invoices;
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transaction references;
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billing information;
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records required for accounting and administration.
Payment-card information is generally processed by the relevant payment provider rather than stored directly by us.
Communications
This may include communications through:
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email;
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website forms;
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booking systems;
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messaging services;
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other agreed communication channels.
Website and technical information
Depending on your choices and the technologies used on the website, this may include information such as:
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IP address;
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browser type;
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device type;
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operating system;
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pages visited;
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referral source;
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general site interaction information;
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cookie or privacy preferences.
Further information is provided under Cookies and Other Storage-and-Access Technologies below.
How We Collect Information
Most personal information is provided directly by you.
This may happen when you:
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make an enquiry;
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complete a form;
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book a service;
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make a payment;
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contact us;
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participate in a coaching or organisational engagement;
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communicate with us during an engagement;
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choose to receive communications from us.
Information may also be received through service providers used to administer the relationship, such as booking, payment, website or communication platforms.
Where an organisation engages us, it may provide basic business contact or participation information concerning relevant organisational contacts or participants.
Website and technical information may also be generated automatically when you use the website, subject to applicable privacy and storage/access technology rules.
How and Why We Use Personal Information
We use personal information only where we have an appropriate purpose and lawful basis.
Depending on the circumstances, this may include the following.
Responding to enquiries
We may use your contact and enquiry information to respond to questions about services and determine whether a proposed engagement should proceed.
The lawful basis may be:
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taking steps at your request before entering into a contract; or
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our legitimate interests in responding to genuine business enquiries.
Booking and administering services
We use information to:
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schedule services;
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communicate about appointments;
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administer engagement arrangements;
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provide agreed services.
The principal lawful basis is normally performance of a contract or taking steps at your request before entering into one.
Providing TRUTH Code™ services
We process relevant information to provide the coaching, formation, workshop, intensive or consulting engagement you have agreed to receive.
The principal lawful basis is normally performance of the relevant contract.
Payments, accounts and business administration
We process appropriate information to:
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administer payments;
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issue invoices;
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maintain accounting records;
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meet tax, company and other applicable legal requirements.
The lawful bases may include:
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performance of a contract;
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compliance with legal obligations.
Protecting safety, professional boundaries and legitimate business interests
We may process relevant information where reasonably necessary to:
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protect the security of our services;
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maintain appropriate professional and business records;
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respond to complaints;
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establish, exercise or defend legal rights;
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manage legitimate health, safety or safeguarding concerns.
The applicable lawful basis depends on the circumstances and may include legal obligation or legitimate interests.
Website operation and improvement
Technical information may be processed to:
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operate and secure the website;
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maintain functionality;
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understand site performance;
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improve the user experience.
The lawful basis and any consent requirements depend on the particular technology and purpose involved.
Further information is provided under Cookies and Other Storage-and-Access Technologies.
Marketing and updates
Where we send marketing or promotional electronic communications, we do so only where permitted by applicable law.
You can unsubscribe from marketing communications at any time.
Special-Category Information
Some information may receive additional protection under UK data-protection law.
Depending on the nature of an engagement, information voluntarily provided by a client could include information relating to matters such as:
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health;
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religious or philosophical beliefs.
We do not require clients to disclose sensitive information merely because it may be personally significant.
Where special-category personal information is intentionally processed, we identify an appropriate lawful basis and an appropriate condition under the UK GDPR.
Where appropriate, this may include your explicit consent.
For example, information concerning health may sometimes be relevant to the safety or suitability of optional embodied practice, while information concerning religious belief may be relevant where a client specifically requests Christian formation.
Special-category information is not used for unrelated marketing or profiling.
Who We May Share Information With
We do not sell personal information.
Personal information may be shared where reasonably necessary with trusted service providers supporting functions such as:
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website hosting;
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online forms;
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booking and scheduling;
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payment processing;
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email and communications;
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online meeting delivery;
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cloud storage;
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business administration;
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accounting or professional advice;
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analytics or website operation where lawfully configured.
Providers are given access only where necessary for the relevant purpose and are subject to their own contractual and legal obligations.
Information may also be disclosed where:
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required by law;
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necessary in connection with legal proceedings;
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reasonably necessary for safeguarding or serious safety concerns;
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appropriate professional consultation or supervision is required.
Where consultation or supervision is used, identifying information is limited as far as reasonably practicable.
International Data Transfers
Some technology and service providers may process personal information outside the United Kingdom.
Where personal information is subject to a restricted international transfer, appropriate safeguards are used where required by applicable data-protection law.
These may include:
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UK adequacy regulations;
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approved contractual safeguards;
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other lawful transfer mechanisms.
The precise arrangements depend on the provider and processing involved.
You may contact us if you would like further information about safeguards relevant to your personal information.
How Long We Keep Information
We do not keep personal information indefinitely merely because it has been collected.
Retention depends on:
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why the information was collected;
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whether an engagement is ongoing;
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applicable accounting or tax requirements;
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contractual obligations;
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insurance or professional-record requirements;
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complaint or legal-claim considerations;
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safeguarding or safety requirements;
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whether continued retention remains reasonably necessary.
Information that is no longer reasonably required is deleted, anonymised or otherwise securely disposed of where appropriate.
Financial and accounting records are retained for the period required by applicable law.
Marketing information is retained until:
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you unsubscribe;
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consent is withdrawn where consent is relied upon;
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there is no longer a legitimate reason to retain it.
We may retain a limited suppression record where necessary to ensure that an unsubscribe or objection continues to be respected.
Cookies and Other Storage-and-Access Technologies
This website may use cookies and other technologies that store information on, or access information from, your device.
These may include technologies used for:
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essential website operation;
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security;
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remembering choices;
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functionality;
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website statistics or analytics;
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marketing, where such technologies are enabled.
Some technologies are necessary for the website or a service you request to function.
Others may require your consent.
Current UK rules also provide limited exceptions for particular purposes where their specific legal conditions are met.
Where consent is required, the relevant non-exempt technology should not be used before that consent has been obtained.
Where an applicable exception is relied upon, we provide the information and user controls required for that exception.
You can review or change your website privacy choices through the site's cookie or privacy-preference control.
The technologies used on the website are reviewed periodically because they may change when website functionality or third-party integrations change.
Website Analytics
We may use website analytics to understand matters such as:
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how many people use the website;
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which pages are visited;
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how visitors move through the website;
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device and browser information;
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general referral information;
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website performance.
The way analytics is configured determines which privacy and consent requirements apply.
We do not use a statistical analytics exception as a general justification for tracking or profiling individual visitors.
Where analytics involves tracking, profiling, advertising measurement or another purpose requiring consent, the relevant technology should remain disabled until the required consent has been obtained.
Your Marketing Choices
You can ask us to stop sending marketing communications at any time.
You may do this by:
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using an unsubscribe option where provided; or
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contacting us directly.
Stopping marketing communications does not prevent us from sending messages reasonably necessary to administer an existing service or contract.
Security
We use reasonable technical and organisational measures intended to protect personal information against:
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unauthorised access;
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inappropriate disclosure;
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accidental loss;
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alteration;
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destruction.
No internet-based system can be guaranteed to be completely secure.
We therefore keep security arrangements under review and use service providers appropriate to the information and services involved.
Your Data-Protection Rights
Depending on the circumstances and lawful basis involved, you may have rights including:
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the right to access your personal information;
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the right to correct inaccurate information;
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the right to request erasure in appropriate circumstances;
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the right to request restriction of processing;
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the right to object to certain processing;
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the right to data portability where applicable;
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the right to withdraw consent where processing is based on consent.
Not every right applies in every circumstance.
We may need to verify your identity before responding to a request.
Your Right to Object
Where we rely on legitimate interests for processing, you may have the right to object to that processing.
You also have the right to object to the use of your personal information for direct marketing.
If you object to direct marketing, we will stop using your information for that purpose.
Withdrawing Consent
Where processing relies on your consent, you may withdraw that consent at any time.
Withdrawal does not make processing carried out before withdrawal unlawful.
Depending on the information involved, withdrawing consent may mean that a particular optional activity or service element can no longer continue.
Complaints
If you have a concern about how your personal information has been handled, please contact us first so that we have an opportunity to address it.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent data-protection regulator.
Children and Eligibility
The website is not designed as a service directed towards children.
Individual TRUTH Code™ coaching, training and formation services are generally provided to adults in accordance with the eligibility terms stated on the website or in the relevant engagement agreement.
If different arrangements apply within an organisational engagement, they are considered separately and subject to appropriate contractual, safeguarding and data-protection arrangements.
Automated Decision-Making
TRUTH Code™ does not use its coaching or Diagnostic processes as automated systems for making decisions that produce legal or similarly significant effects about individuals.
Where technology is used for routine administration, scheduling, payments or website operation, it does not replace practitioner judgement in the provision of TRUTH Code™ coaching and formation services.
Changes to This Privacy Notice
This Privacy Notice may be updated where:
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our services change;
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the technologies we use change;
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our processing activities change;
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legal or regulatory requirements change.
The latest version will be published on this website with the relevant update date.
Where a change materially affects how existing personal information is used, additional notice will be provided where appropriate.
Contact Us
For questions about this Privacy Notice, personal information held about you or your data-protection rights, contact:
Truth Code Coaching and Consulting Ltd
124 City Road
London
EC1V 2NX
United Kingdom
Email: info@obiokolo.com