1. Who is responsible for your information
The data controller is Mark Polereczky, a sole trader trading as Crossroads Clarity.
Business location: Norwich, United Kingdom
Email: info@crossroadsclarity.net
For any privacy question or request, use the email address above.
2. Information collected
Depending on how you interact with Crossroads Clarity, I may collect:
- identity and contact information, such as your name, email address, country, time zone and any telephone number you choose to provide;
- booking information, including appointment dates, availability and confirmation records;
- transaction information, including payment status, amount, currency, VAT and refund records, but not your full card details;
- career and professional information, including employment history, responsibilities, interests, goals, constraints and information in the Crossroads Snapshot;
- coaching information, including session notes, an optional transcript, the Crossroads Map, career experiment and check-in correspondence;
- communications, enquiries, complaints and support requests;
- feedback, testimonial permissions and the way you have agreed to be identified; and
- limited technical and security information processed automatically by the website-hosting and communications providers, such as IP address, browser or device information and essential server logs.
Crossroads Clarity does not currently use Google Analytics, advertising pixels or behavioural tracking on the website.
3. Sensitive information
Career conversations can sometimes include health, mental-health, disability, racial or ethnic origin, religious or philosophical beliefs, sexual orientation, trade-union membership or other sensitive information. You are not required to provide this information unless you consider it relevant.
Where special-category information is voluntarily provided and used to deliver the service, I will normally rely on your explicit consent in addition to the relevant ordinary lawful basis. You may withdraw that consent, but doing so may limit what can be discussed or recorded and does not make earlier lawful processing unlawful.
Please do not provide detailed medical records or sensitive information that is not reasonably relevant to career coaching.
4. How information is obtained
Most information comes directly from you when you email, book, pay, complete the Crossroads Snapshot, attend a session, request support or provide feedback. Booking and transaction information may also be received from Calendly and Stripe. Technical information may be generated automatically by the services used to operate the website and online sessions.
5. Purposes and lawful bases
I use personal information for the following purposes:
- To answer enquiries, manage bookings, take payment, deliver the Intensive, prepare the Crossroads Map and provide the check-in. The lawful basis is taking steps at your request before entering a contract and performing the contract.
- To maintain tax, VAT, accounting and legally required records, respond to lawful requests and meet consumer-law obligations. The lawful basis is compliance with legal obligations.
- To administer and protect the website, accounts, communications and service; prevent misuse; improve internal processes; and establish, exercise or defend legal claims. The lawful basis is legitimate interests in operating a secure, effective and accountable coaching practice, balanced against your rights.
- To create a transcript. The lawful basis is consent. If sensitive information is included, explicit consent is also used as the special-category condition.
- To publish a testimonial. The lawful basis is consent.
- To send optional email updates or marketing where you have chosen to receive them, or where the limited customer soft opt-in is lawfully available and properly offered. Every marketing email will provide a way to unsubscribe.
6. When information is required
Some information is necessary to enter into or perform the contract, including your name, contact details, booking information, payment confirmation and enough information to conduct the coaching session. If you do not provide it, I may be unable to accept the booking or provide the service. Other information, including testimonial, marketing and transcription consent, is optional.
7. Sharing information
Personal information may be shared only where reasonably necessary with:
- Calendly, for scheduling and booking administration;
- Stripe, for payments, refunds and fraud prevention;
- Google services, including Gmail, Google Meet and Google Drive, for communications, sessions and secure document storage;
- Zoom, when used for an online session or transcription;
- OpenAI's ChatGPT Sites and related website infrastructure, for operating and securing the website;
- the online-form or questionnaire provider used to collect Crossroads Snapshot responses, when applicable;
- professional advisers such as an accountant, lawyer or insurer where reasonably necessary and subject to professional or contractual confidentiality;
- courts, regulators, tax authorities, law enforcement or emergency services where disclosure is required by law or reasonably necessary to respond to an immediate and serious risk of harm; and
- a purchaser or successor if the business is sold or reorganised, subject to appropriate confidentiality and data-protection safeguards.
Crossroads Clarity does not sell personal information and does not share it for cross-context behavioural advertising.
8. International transfers
Crossroads Clarity is established in the UK but operates online while Mark Polereczky may be in the UK or Dubai. Some service providers may process information in the United States, the United Arab Emirates or other countries outside the UK.
Where UK data-protection law requires a safeguard for a restricted transfer, I will rely on an applicable UK adequacy regulation, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, or another lawful safeguard or exception. Provider security measures and contractual protections will be considered before sensitive client information is transferred.
9. Retention
Personal information is kept only for as long as reasonably necessary for the purpose for which it was collected, including legal, accounting and dispute requirements. The usual periods are:
- enquiries that do not become bookings: up to 12 months after the last communication;
- Snapshots, coaching notes, transcripts, Crossroads Maps and check-in correspondence: up to three years after the last service;
- temporary audio used to produce a transcript: deleted once the transcript has been produced and checked; no video is retained;
- contracts, invoices, payment, VAT and accounting records: normally six years after the relevant transaction or financial period;
- complaints and records relevant to a legal claim: normally up to six years after closure, or longer where a claim or legal requirement makes this necessary;
- testimonial material: until permission is withdrawn or the testimonial is no longer used, with a record of consent retained as reasonably necessary to demonstrate compliance; and
- unsubscribe or objection records: a minimal suppression record may be kept for as long as necessary to ensure that you are not contacted again.
Information may be deleted earlier when it is no longer needed, or retained longer where required by law, a regulator, litigation hold or an active dispute.
10. Security
Reasonable technical and organisational measures are used to protect personal information. These include access controls, password-protected accounts, reputable service providers, limited access, secure cloud storage and deletion or anonymisation when information is no longer required.
No online system is completely secure. If a personal-data breach is likely to create a risk to individuals, it will be assessed and reported to the Information Commissioner's Office and affected individuals where the law requires.
11. Transcription
Transcription is optional and requires separate consent. If you consent, the transcript is used to support accurate notes and preparation of your Crossroads Map. No video recording is retained. Any temporary audio used solely to generate the transcript is deleted after the transcript has been produced and checked. If you decline, written notes will be taken instead.
12. Your rights
Depending on the circumstances, UK data-protection law gives you the right to:
- ask for access to your personal information;
- ask for inaccurate information to be corrected;
- ask for information to be deleted;
- ask for processing to be restricted;
- object to processing based on legitimate interests;
- object at any time to direct marketing;
- receive certain information in a portable format;
- withdraw consent at any time where processing relies on consent; and
- complain to the Information Commissioner's Office.
To exercise a right, email info@crossroadsclarity.net. I may request enough information to verify your identity. Requests are normally answered within one month, although the law permits an extension for particularly complex or numerous requests.
You have an absolute right to object to the use of your personal information for direct marketing. Email info@crossroadsclarity.net or use the unsubscribe link in any marketing email.
13. Complaints
Please contact info@crossroadsclarity.net first so I can try to resolve a concern. You also have the right to complain to the UK Information Commissioner's Office at www.ico.org.uk or by calling 0303 123 1113. If you live outside the UK, you may also have the right to complain to a local privacy regulator.
14. Children
The website and service are intended only for people aged 18 or over. Crossroads Clarity does not knowingly collect personal information from children. If you believe a child has provided information, email info@crossroadsclarity.net so it can be investigated and deleted where appropriate.
15. Automated decisions
Crossroads Clarity does not use solely automated decision-making or profiling that produces legal or similarly significant effects. Career conclusions and materials are developed through human coaching and review.
16. Cookies and website technologies
The website may use cookies or similar technologies that are strictly necessary to provide, secure or remember choices on the site. The website does not currently use optional analytics, advertising or behavioural-tracking cookies.
If non-essential cookies or analytics are introduced, this Policy will be updated and UK visitors will be asked for consent before those technologies are used, unless a legal exemption applies.
17. External links
The website may link to third-party sites and services. Their privacy practices are controlled by them. You should review their notices before providing personal information directly to them.
18. Changes to this Policy
This Privacy Policy may be updated when the service, providers or law changes. The updated version will be posted on the website with a new effective date. Material changes may also be communicated directly where appropriate.