DI CUMING CREATES LTD PRIVACY POLICY

Effective date: 13 September 2026
Last updated: 13 September 2026

1. Who we are

This Privacy Policy explains how Di Cuming Creates Ltd collects, uses, stores and protects personal information.

Di Cuming Creates Ltd is the data controller.

Company number: 17417619
Registered office: 57 Primrose Street, Lancaster, LA1 3BN, United Kingdom
Email: [email protected]

This policy applies when you:

visit our websites, landing pages, sales pages or online platforms;

join our email list;

request a free guide or resource;

purchase or participate in a programme, course or other service;

receive 1:1 coaching or mentoring;

join an online community or live session;

otherwise interact with Di Cuming Creates Ltd.

Our services are intended for adults aged 18 and over.

2. Personal information we collect

Depending on how you interact with us, we may collect:

Identity and contact information, including your name, email address, postal or billing address, telephone number where provided, account details and communication preferences.

Purchase and transaction information, including what you purchased, payment status, billing information and limited payment information.

Payments are processed by providers such as Stripe. We do not normally receive or store your full debit or credit card number or security code.

Communications and service information, including emails, enquiries, coaching or programme communications, community posts, questions, feedback, surveys and material you choose to share.

Subscription and free-resource information, including resources requested, subscription details and marketing preferences.

Technical and usage information, which our websites and online platforms may collect automatically, including IP address, browser or device information, login information, pages or features used, access dates and times, and security information.

Marketing information, including your marketing preferences and, where available, email opens, links clicked and unsubscribes.

3. Special category information

We do not normally ask you to provide sensitive or special category personal information.

You may choose to disclose information about matters such as health, ethnicity, religious or philosophical beliefs, political opinions or sexual orientation during coaching, programmes, communities or other communications.

We will only process special category information where we have a lawful basis and an additional condition permitted by data-protection law. Where appropriate, this may include your explicit consent.

4. How we use your information

We may use personal information to:

provide free and paid products, resources and services;

provide coaching, programmes, courses, workshops and events;

create and manage accounts and communities;

process purchases and payments;

communicate with you about something you have requested, registered for or purchased;

deliver and record live sessions;

provide customer support;

administer and protect our business;

improve our services;

send marketing communications where permitted;

meet legal, tax, accounting and regulatory obligations; and

establish, exercise or defend legal rights.

5. Our lawful bases

We process personal information under one or more of the following lawful bases:

Contract

Where processing is necessary to provide something you have purchased or registered for, or to take steps at your request before entering into a contract.

Legal obligation

Where processing is necessary to meet legal, tax, accounting or regulatory requirements.

Legitimate interests

Where processing is necessary to operate, administer or protect our business, improve our services, respond to communications, maintain records, prevent misuse or deal with legal claims, provided your rights do not override those interests.

Consent

Where consent is the appropriate lawful basis, we will ask for it clearly. This may include certain marketing communications, promotional use of testimonials or other identifiable material, and some uses of special category information.

Where we rely on consent, you may withdraw it at any time. This does not affect processing carried out lawfully before consent was withdrawn.

6. Email and marketing

Our main customer and marketing communication system is SOMBA.io, a branded version of the HighLevel (GoHighLevel) platform.

SOMBA.io may hold your name, email address, contact details, purchase information, marketing preferences and communications with us.

We may occasionally use another email service, such as Gmail, for direct administrative or service-related communication.

We send marketing communications where permitted by law.

You can unsubscribe from marketing at any time. Unsubscribing from marketing does not prevent us from sending communications necessary to provide a service you have purchased, requested or registered for.

7. Live sessions and recordings

We currently use Zoom for live online sessions and coaching calls.

Some sessions may be recorded. Participants will be told when recording takes place.

Recordings may be used for service delivery or other purposes made clear to participants in advance.

We will not use identifiable participant contributions publicly or for promotional purposes without an appropriate lawful basis and, where required, their permission.

8. Online communities

We may provide private communities through SOMBA.io, Facebook or another suitable platform and may change platforms where reasonably necessary.

Information you choose to post in a private community may be visible to other participants who have access to that community.

A third-party platform may also process information under its own privacy terms.

9. Who we share information with

We do not sell your personal information.

We use service providers where necessary to operate our business and deliver our services. These may include:

SOMBA.io;

payment providers such as Stripe;

Zoom;

Meta/Facebook, where we use its services;

email, website, hosting, cloud-storage, IT, analytics and security providers; and

accountants, lawyers and other professional advisers.

We may also disclose information where required by law, to regulators or authorities, or where necessary to establish, exercise or defend legal rights.

If the business is sold, reorganised or transferred, relevant information may be transferred where permitted by law.

10. International transfers

Some service providers may process personal information outside the UK or European Economic Area.

Where required, we will use an appropriate lawful transfer mechanism.

11. How long we keep information

We keep personal information only for as long as necessary for the purposes for which it was collected, including providing services, meeting legal and accounting obligations, and dealing with disputes or legal claims.

Financial, transaction and contractual records may generally be kept for up to six years, or longer where required by law.

Other information is kept only for as long as reasonably necessary.

12. Data security

We use appropriate technical and organisational measures to protect personal information against loss, misuse, unauthorised access, alteration or disclosure.

If a personal data breach occurs, we will take the action required by applicable data-protection law.

13. Cookies and similar technologies

Our websites, landing pages, sales pages and online platforms may use cookies and similar technologies.

Where required by law, we will obtain consent before using non-essential cookies or similar technologies.

14. Your data-protection rights

Depending on the law that applies, you may have rights to:

access your personal information;

correct inaccurate information;

request erasure or restriction in certain circumstances;

object to certain processing;

receive certain information in a portable format; and

withdraw consent where we rely on consent.

To exercise your rights, contact [email protected].

We would appreciate the opportunity to resolve any concern first, so please contact us before making a formal complaint where possible.

You also have the right to complain to the UK Information Commissioner’s Office (ICO) or, where applicable, the relevant data-protection authority in your country.

15. Changes to this policy

We may update this Privacy Policy when our business, services, technology or legal obligations change.

The current version will show the date it was last updated. Where required by law, we will notify you of significant changes affecting how we use your personal information.

16. Contact

Di Cuming Creates Ltd
Company number: 17417619
57 Primrose Street
Lancaster
LA1 3BN
United Kingdom

Email: [email protected]