Divergent Pathways

Privacy Policy

Last updated: June 2026

This policy explains how Divergent Pathways collects, uses, and protects your personal information. We are committed to handling your data with care, particularly given the sensitive nature of the support we provide to neurodivergent individuals and their families.

Please read this policy before using our website or services. If you have any questions, contact us at claire@divergentpathways.co.uk.

1. Who we are

Divergent Pathways is operated by Claire Douglas, based in the West Midlands, UK.

Data controller contact:

• Name: Claire Douglas, Divergent Pathways

• Email: claire@divergentpathways.co.uk

• Website: www.divergentpathways.co.uk

We are not currently registered with the Information Commissioner's Office (ICO) as a data controller, as we fall within the small organisation threshold. However, we comply fully with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. What information we collect and why

We collect personal information in the following ways:

Website enquiries and contact form

• What: your name, email address, and the content of your message

• Why: to respond to your enquiry and provide information about our services

• Legal basis: legitimate interests

Mailing list sign-up

• What: your name and email address

• Why: to send you resources, guidance, and updates relevant to neurodivergent families

• Legal basis: consent. You can unsubscribe at any time using the link in any email we send

Coaching clients — pre-session forms

• What: information you share about yourself or the person you are supporting, including any relevant background, goals, or challenges

• Why: to prepare for your coaching session and make the best use of your time

• Legal basis: performance of a contract (your coaching agreement with us)

Coaching clients — session summaries

• What: a written summary of themes explored, insights, and agreed next steps

• Why: to support your ongoing progress and provide a record you can return to

• Legal basis: performance of a contract

Paid resource purchases

• What: your name and email address, and payment information processed securely by our platform

• Why: to fulfil your purchase and deliver the resource

• Legal basis: performance of a contract

Website usage data

• What: information about how you use our website, collected via Google Analytics (including pages visited, time on site, approximate location, device type)

• Why: to understand how our website is used and improve it

• Legal basis: legitimate interests. You can opt out of Google Analytics tracking at tools.google.com/dlpage/gaoptout

3. A note on working with young people

Some of our services support young people, including those under 18. Where we work with a young person, we ask that a parent or carer makes initial contact and gives consent before any coaching takes place.

We handle information about young people with particular care. We do not share it with any third party without explicit parental or carer consent, except where we are legally required to do so (for example, in situations involving risk of serious harm).

4. How long we keep your information

• Enquiry and contact form data: 12 months from the date of your last contact with us

• Mailing list data: until you unsubscribe

• Coaching pre-session forms and session summaries: 24 months from the end of your coaching relationship with us, after which they are securely deleted

• Purchase records: 6 years, in line with HMRC requirements for financial records

• Website analytics data: as per Google Analytics retention settings (default 26 months)

If you would like us to delete your information sooner, please contact us at claire@divergentpathways.co.uk and we will action this unless we are legally required to retain it.

5. Who we share your information with

We do not sell your personal data. We share it only with the following third-party service providers who help us deliver our services:

Funnel Sketchers Ltd (UK-based)

• Purpose: email marketing, mailing list management, landing pages, and processing payments for digital resources

• Location: Funnel Sketchers Ltd is a UK-registered company headquartered in Wales. They are subject to UK GDPR. See their privacy policy at funnelsketchers.com/privacy-policy

Microsoft (OneDrive and Word)

• Purpose: secure storage of coaching notes, pre-session forms, and session summaries

• Location: Microsoft stores data in accordance with UK GDPR. See their privacy policy at microsoft.com/privacy

Google Analytics

• Purpose: website usage analytics

• Location: Google LLC is US-based. Data transfers are covered by Standard Contractual Clauses. See Google's privacy policy at policies.google.com/privacy

Hostinger (website hosting)

• Purpose: hosting the divergentpathways.co.uk website

• Location: Hostinger operates data centres within the EU/EEA. See their privacy policy at hostinger.co.uk/privacy-policy

We do not share your personal information with any other third parties without your explicit consent, except where required by law.

6. Your rights under UK GDPR

As a UK resident, you have the following rights regarding your personal data:

• The right to be informed about how we use your data (this policy fulfils that obligation)

• The right to access the personal data we hold about you

• The right to rectification if the data we hold is inaccurate or incomplete

• The right to erasure (‘the right to be forgotten’) in certain circumstances

• The right to restrict processing in certain circumstances

• The right to data portability (to receive your data in a structured, commonly used format)

• The right to object to processing based on legitimate interests

• Rights in relation to automated decision-making (we do not use automated decision-making or profiling)

To exercise any of these rights, contact us at claire@divergentpathways.co.uk. We will respond within one calendar month.

7. Cookies

Our website uses cookies. These are small files placed on your device when you visit our site. We use:

• Essential cookies: required for the website to function correctly

• Analytics cookies: placed by Google Analytics to help us understand how visitors use our site

You can manage or disable cookies through your browser settings. Disabling analytics cookies will not affect your ability to use our website.

8. Links to other websites

Our website may contain links to external websites, including resources and organisations we recommend. We are not responsible for the privacy practices of those sites and encourage you to read their privacy policies before providing any personal information.

9. How to complain

If you have concerns about how we handle your personal data, please contact us first at claire@divergentpathways.co.uk and we will do our best to resolve it.

If you remain unhappy, you have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK’s data protection authority:

• Website: ico.org.uk

• Phone: 0303 123 1113

We would always appreciate the opportunity to address your concern directly before you contact the ICO.

10. Changes to this policy

We may update this policy from time to time. When we do, we will update the ‘last updated’ date at the top of this page. We encourage you to review this policy periodically.

Divergent Pathways | claire@divergentpathways.co.uk | www.divergentpathways.co.uk

Your path. Your pace. Your way.