Privacy and cookies

Last updated: [To confirm: date of publication]

This notice explains what personal data we collect through tdc101.com and in running our business, why we use it, who we share it with, how long we keep it and what your rights are. It also explains the cookies and similar technologies on the site.

The short version

• We only load Google Analytics if you press "Accept analytics". If you say no, nothing is sent to Google for analytics.
• We use no advertising cookies.
• When you sign up, book a call, take the Visibility Score or send us a message, we use what you give us to reply, send what you asked for and understand which pages and posts brought you to us.
• We never sell your data.
• You can ask to see, correct or delete your data at any time. Email k@tdc101.com.

1. Who we are

The Digital Coach Limited, trading as The Digital Collective ("TDC", "we", "us"), is the controller of the personal data described in this notice, unless we say otherwise.

We have not appointed a data protection officer because the law does not require us to. [To confirm: solicitor to confirm a data protection officer is not required] Kenneth Nel is responsible for data protection at TDC. Email him at k@tdc101.com about anything in this notice.

[To confirm: whether TDC needs a representative in the EU under Article 27 of the EU GDPR, because TDC offers services to people in Europe. If one is appointed, add their name and contact details here]

2. What we collect and where it comes from

2.1 When you browse the site

• Analytics, only if you accept. If you press "Accept analytics", Google Analytics 4 records the pages you view, how you arrived (for example a search engine or a link we posted), the buttons and links you click, when you start or send a form, when you book a call, your device and browser type, and your approximate location worked out from your IP address. Google Analytics 4 does not log or store full IP addresses. If you press "No thanks", Google Analytics does not load.
• Where you came from. If you arrive through a link with tracking tags (UTM tags, such as "utm_source=linkedin"), or from a search engine or an AI assistant such as ChatGPT or Perplexity, the site notes that source and the first page of your visit. This is kept in your browser's memory for the page you are on. If you have accepted analytics, it is also kept in your browser's session storage until you close the tab. It is attached to any form you send, booking you make or quiz you take, so we know which post or page led to it. It does not identify you on its own.
• Server logs. Our host, Vercel, records technical information about each request to the site, such as your IP address, the page requested, the time and your browser type. This keeps the site working and secure. [To confirm: how long Vercel keeps these logs on our plan]
• Your cookie choice. The site stores your "Accept analytics" or "No thanks" choice in your browser so it does not ask you on every page.

2.2 When you sign up to The Bridge newsletter

We collect your email address and, if you give it, your first name. We also record the article or page you signed up on, the first page of your visit and the tracking tags you arrived with. This goes to Kit, our email platform. Kit sends you an email asking you to confirm. You are only added once you confirm.

When we send the newsletter, Kit records whether you open it and which links you click. [To confirm: whether open and click tracking is switched on in Kit]

2.3 When you use the contact form

We collect your name, email address, what you do, your message, the page you sent it from and the tracking tags you arrived with. The form is handled by Formspree, which passes your message to our inbox.

2.4 When you book a free Check or a start call

Booking links open Calendly over our page. Calendly collects your name and email address and the answers to our booking questions. These are your LinkedIn profile web address, who your ideal client is, what you have tried already, what a client is worth to you and anything else you want us to know. The booking also carries the tracking tags you arrived with. Calendly tells our page when you pick a time and when you book, so we can count bookings (only if you have accepted analytics).

Before the call we may look at the public LinkedIn profile you gave us, so the call is useful to you.

The call takes place on [To confirm: Google Meet, Zoom or another tool]. [To confirm: whether calls are recorded or transcribed, for example with Otter.ai or Zoom. If they are, say so here, say why, say how long recordings are kept, and tell people at the start of each call]

2.5 When you take the LinkedIn Visibility Score

The Visibility Score is a quiz run by ScoreApp. It is shown on our page from linkedinvisibility.tdc101.com. ScoreApp collects your first name and email address before the questions, then your answers. It works out your score automatically and sends you your result and the Visibility Score Playbook. ScoreApp shares your details, answers and score with us. The quiz link also carries the page and the tracking tags that sent you there. [To confirm: any other questions the quiz asks, such as phone number or company, and whether ScoreApp passes quiz takers to Kit or to any other tool]

2.6 When you email us or message us

We keep the emails and messages you send us and our replies, including your name, email address and anything you choose to tell us.

2.7 When you watch a video on the site

Videos are shown as a still picture first. The picture is loaded from YouTube's image server, which receives your IP address. YouTube only loads when you press play. It then runs in YouTube's privacy-enhanced mode (youtube-nocookie.com). Once a video plays, YouTube (Google) may store information on your device and collect information about your viewing under Google's own privacy policy.

2.8 When you become a client

If you buy our services we collect your name, business name, email address, billing details, the PayPal email address you pay from, and the information we need to do the work. That includes your ideal client, your exclusion list and the LinkedIn activity we carry out for you. You pay through PayPal. We never see or store your card or bank details. PayPal tells us your name, email address, payment amounts, dates and status.

Our operators work on your own LinkedIn account, on your instructions. When they do, they see the personal data of the people in your network and the people you ask us to contact. For that data you are the controller and we act for you as your processor. How we handle it is set out in our Service Terms. [To confirm: solicitor to confirm this controller and processor split, and that the Service Terms will include a data processing agreement under Article 28 of the UK GDPR]

2.9 When we contact you on LinkedIn

We grow our own network on LinkedIn too. If we send you a connection request or a message from a TDC account, we use the information on your public LinkedIn profile (such as your name, job title, company and location) and what you say in reply. We get this from LinkedIn, not from you directly. [To confirm: which TDC accounts this covers, and whether any of this is copied into another tool such as ClickUp, Kondo or a spreadsheet]

2.10 Data we do not want

Please do not send us sensitive information, such as health details, in a form, booking or message. We do not need it.

3. Why we use your data and our lawful basis

UK data protection law says we must have a lawful basis for each use. These are ours.

Where we rely on legitimate interests, we have weighed our interest against your rights. You can object at any time (see section 8).

Automated scoring. Your Visibility Score is worked out automatically from your answers. It is a guide only. It has no legal effect on you and we do not use it to make any decision that significantly affects you.

4. Marketing

We only send marketing emails if you have agreed to receive them. Every email has a one-click unsubscribe link. You can also email k@tdc101.com to stop them. If you unsubscribe, we keep your email address on a suppression list so we do not email you again by mistake.

5. Who we share your data with

We never sell your data. We share it only with the providers who run parts of our business for us (processors), or who provide a service to you under their own terms (independent controllers). Our processors may only use your data on our instructions.

Our team. Our operators, project managers and coaches can see the data they need to do their job. Some of them work outside the UK. [To confirm: the countries where team members and contractors work, and that each has a written contract with confidentiality and data protection terms]

Others. We may share data with our professional advisers, with a buyer if we sell our business, or where the law requires it, for example with HMRC or the police.

6. International transfers

Some of the providers and team members above are outside the UK. When your data goes outside the UK we make sure it is protected by one of these:

• a UK adequacy decision (the UK government has found that the country protects personal data properly), for example the countries of the European Economic Area
• for US providers certified under the UK Extension to the EU-US Data Privacy Framework, that certification
• otherwise, the UK International Data Transfer Agreement or the UK Addendum to the EU standard contractual clauses.

[To confirm: for each provider and each country where team members work, which of these applies. Check each US provider on the Data Privacy Framework list at dataprivacyframework.gov]

You can ask us for more detail on the safeguards for any transfer. Email k@tdc101.com.

7. How long we keep your data

We keep data only as long as we need it. These are our current periods. [To confirm: each period below, and set the matching settings in each tool]

8. Your rights

You have these rights under UK data protection law:

• Access. Ask for a copy of the personal data we hold about you.
• Correction. Ask us to correct data that is wrong or incomplete.
• Deletion. Ask us to delete your data.
• Restriction. Ask us to limit how we use your data, for example while we check it is accurate.
• Objection. Object to our use of your data where we rely on legitimate interests. You can always object to direct marketing, and we will stop.
• Portability. Ask for data you gave us, in a common electronic format, or ask us to send it to someone else, where we rely on your consent or a contract.
• Withdraw consent. Where we rely on your consent, withdraw it at any time. This does not affect what we did before.

Some rights have limits. We will tell you if one applies.

How to use your rights. Email k@tdc101.com, or write to The Digital Coach Limited, The White Building, 33 Kings Road, Reading, RG1 3AR. You can also send Kenneth Nel a message on LinkedIn, but email is quickest. You do not need to use any form or particular words. It is free. We may ask you to confirm who you are. We will reply within one month. If your request is complex we may need up to two more months, and we will tell you why within the first month.

9. Cookies and similar technologies

Cookies are small files a website stores on your device. Similar technologies include local storage and session storage in your browser. The law says we must ask before we store or read anything on your device, unless it is strictly necessary for something you asked for.

We use no advertising cookies. Our fonts are stored on our own site, so no font provider is involved.

Changing your choice. Use the "Cookie settings" link at the bottom of every page to change your choice at any time. [To confirm: this link is added to the site before this notice is published] You can also clear this site's data in your browser settings and reload the page, and the site will ask you again. If you withdraw consent, Google Analytics stops loading. You can also delete Google Analytics cookies already set in your browser settings.

10. Security

We use providers with strong security. The site runs only over a secure connection (HTTPS) and has strict security settings. Access to personal data in our tools is limited to the people who need it, using individual logins. No card or bank details ever reach our site. No method is perfect, so if a breach affects you in a serious way, we will tell you and the ICO as the law requires.

11. Children

The site and our services are for businesses and professionals aged 18 or over. We do not knowingly collect data from anyone under 18. If you think we have, email k@tdc101.com and we will delete it.

12. Complaints

If you are unhappy with how we have used your data, please tell us first. Email k@tdc101.com with "Data protection complaint" in the subject, or write to us at the address in section 1. We will acknowledge your complaint within 30 days, look into it without undue delay, keep you updated and tell you the outcome.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK data protection regulator:

• Website: ico.org.uk/make-a-complaint
• Phone: 0303 123 1113
• Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

If you live in the European Economic Area, you can also complain to the data protection authority in your country.

13. Online checkout

[ADD THIS SECTION ONLY WHEN PAYPAL CHECKOUT IS SWITCHED ON. KENNETH TO CONFIRM: wording with the solicitor at that time]

You can start some packages online with a PayPal subscription. When you press the PayPal button, PayPal's checkout loads on our page and PayPal collects your payment details under its own privacy notice. PayPal may use cookies and similar technologies to process the payment and prevent fraud. PayPal tells us your name, email address, the package, your subscription number and the payment status. We also send PayPal a short reference showing the package and the post or page that brought you to us, so we know which pages lead to sales. If you have accepted analytics, Google Analytics records that a checkout started and finished, the package and its price.

When this section is added, also: add PayPal's checkout cookies to the table in section 9 with their consent status, add "Set up and manage your subscription" (lawful basis: performing our contract) to the table in section 3, and update the retention table for subscription records.

14. Changes to this notice

We may update this notice when our tools or the law change. The date at the top shows when it last changed. If we make a change that matters to you, such as a new use of your data, we will tell you by email where we have your address, or with a notice on the site.

15. Contact

The Digital Coach Limited, trading as The Digital Collective The White Building, 33 Kings Road, Reading, RG1 3AR Email: k@tdc101.com

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Solicitor notes (remove before publishing)

1. Controller and processor split for client LinkedIn accounts (2.8). Please confirm TDC acts as processor when operators work on a client's own account, and draft the Article 28 terms into the Service Terms. If TDC decides who to contact or keeps prospect data for its own use, it may be a joint or independent controller instead.
2. Prospects contacted on LinkedIn (2.9). This section is the Article 14 notice for people TDC contacts for its own network. Consider whether a link to this notice should appear in the TDC profile or first message, given Article 14(3).
3. EU representative (section 1). TDC offers services into Europe. Please advise whether Article 27 of the EU GDPR requires an EU representative.
4. Marketing consent (sections 3 and 4). The quiz, the booking form and the contact form must not lead to marketing emails without consent where the person is an individual subscriber, such as a sole trader (Privacy and Electronic Communications Regulations 2003, regulation 22). The soft opt-in is doubtful for a free quiz.
5. Email tracking (2.2). The ICO's storage and access guidance treats tracking pixels in emails like cookies. Please confirm the sign-up wording is enough, or whether open tracking should be switched off.
6. Analytics consent. The Data (Use and Access) Act 2025 added an exception for statistical cookies from 5 February 2026. It needs a simple way to object, and the provider may only use the data to improve our site. Google Analytics in its usual set-up is not clearly within it, so this notice keeps consent first. Please confirm.
7. Embedded third parties (section 9). The ScoreApp quiz loads with the Visibility Score page. A cookie scan of that page, the Calendly pop-up and a playing YouTube video is needed before this table is final.
8. US state privacy laws. TDC is unlikely to meet the thresholds for the California Consumer Privacy Act and similar laws today. Please confirm, given the plan to grow to many more clients.
9. Retention (section 7). The proposed periods are suggestions. Please confirm they are reasonable.