The Freedom Game and Marie Cowgill
Last updated: 15 October 2026
This Privacy Policy explains how Cowgill Consulting Ltd collects, uses, stores and protects personal information when you interact with Marie Cowgill, The Freedom Game or related coaching, mentoring, strategy, educational and digital services.
This includes when you:
Visit our websites, pages or online profiles;
Complete a form or questionnaire;
Download a resource;
Join a mailing list;
Make an enquiry;
Book or attend a session;
Enter into an ongoing coaching or mentoring relationship;
Communicate with us before, during or after a service;
Purchase a product or service; or
Otherwise interact with us.
1. Who we are
The data controller is:
Cowgill Consulting Ltd
Company number: 16478115
Registered office:
124 City Road
London
United Kingdom
EC1V 2NX
Cowgill Consulting Ltd provides coaching, mentoring, strategy support, educational resources and related services under the Marie Cowgill and The Freedom Game brands.
For privacy questions or requests, contact:
2. Our approach to personal information
Coaching and mentoring can involve personal, professional and sometimes sensitive conversations.
Our approach is to collect and retain information that is reasonably relevant to:
Delivering services;
Maintaining useful continuity;
Supporting the Client;
Administering the professional relationship;
Meeting legal and business obligations; and
Operating and improving our services.
We aim to avoid collecting or retaining unnecessary detail.
This means that information is not automatically recorded merely because it has been mentioned during a conversation.
Where detailed information is not reasonably necessary, we may:
Not record it at all;
Record only the relevant outcome or context;
Use a more general description; or
Ask whether you want a particular fact recorded where remembering it could genuinely help us support you.
For example, a coaching note may record:
“Personal matter discussed; relevant to current confidence and decision-making.”
rather than storing unnecessary details of the personal matter itself.
Equally, where a Client wants Marie to remember something specific because it affects how they would like to be supported, Marie may ask whether the Client wants that information recorded.
3. Information we may collect
Depending on how you interact with us, we may collect and process the following types of information.
Contact and identity information
This may include:
name;
email address;
telephone number;
postal address;
business or organisation details;
job title or professional role; and
other contact information you provide.
Enquiry, form and booking information
This may include:
enquiry details;
booking details;
appointment dates and times;
questionnaire and form responses;
goals, priorities and areas where you are seeking support;
information supplied before a session;
rescheduling and cancellation information; and
relevant correspondence.
Coaching, mentoring and client information
Where you work with us, we may process information including:
information you choose to share during or between sessions;
coaching goals;
agreed actions and priorities;
relevant personal, professional or business context;
communications relating to the coaching relationship;
reasonable professional coaching notes;
session-related working notes;
reflective-practice records;
follow-up notes;
action summaries;
goals or priorities identified during coaching;
information reasonably useful for maintaining continuity; and
information reasonably required to administer or support the professional relationship.
Professional coaching notes are not necessarily verbatim records or complete transcripts of everything discussed.
4. How we approach sensitive information
Coaching conversations may sometimes include sensitive or deeply personal information.
Depending on what an individual chooses to discuss, this may include information concerning matters such as:
physical or mental health;
disability;
neurodivergence;
racial or ethnic origin;
religious or philosophical beliefs;
sexual orientation;
sex life;
trade-union membership; or
other information given additional protection under data-protection law.
We do not seek or routinely record sensitive or special-category personal information merely because it has been mentioned during a coaching conversation.
We aim to follow a data-minimisation approach.
Where detailed sensitive information is not reasonably necessary for an identified purpose, it may:
not be recorded;
be recorded only in a generalised way; or
be excluded from formal coaching notes even though it formed part of the conversation.
For example, a professional note may record:
“Significant personal matter discussed.”
rather than retaining unnecessary intimate detail.
Where a particular sensitive fact would be genuinely useful to retain for an identified coaching purpose, Marie may ask whether the Client wants that information recorded.
This might arise, for example, where a Client wants Marie to remember:
a disability;
neurodivergence;
a health condition;
an adjustment need;
a communication preference connected with a relevant condition; or
another matter that could reasonably affect how future coaching is structured or delivered.
Where appropriate, a note may record both:
the relevant information; and
that the Client expressly requested or agreed that it be recorded for the stated purpose.
For example:
“Client expressly requested that it is recorded that they have ADHD so that future coaching can be structured with this in mind.”
We do not intentionally retain detailed sensitive information merely because it might possibly become useful in the future.
5. Information about other people
Clients may sometimes mention partners, family members, colleagues, employees, business contacts or other people during coaching conversations.
We ask Clients to avoid sharing unnecessary personal information about third parties.
Where information about another person is relevant to the coaching relationship, we aim to record only what is reasonably necessary.
For example, it may be useful for continuity to record:
a partner’s first name;
a child’s first name;
a colleague’s role; or
the existence of a relevant relationship or situation.
We do not seek to build unnecessary profiles of people who are not our Clients.
6. Payment and transaction information
We may process information including:
payment status;
transaction records;
subscription or recurring-payment status;
Direct Debit mandate status;
billing information;
failed-payment information;
refund information; and
payment-provider references.
We do not ordinarily store full payment-card details or full online-banking credentials ourselves.
Payments and Direct Debit arrangements may be administered by third-party payment providers.
7. Marketing and communication information
We may collect and process:
marketing preferences;
consent records;
unsubscribe information;
email engagement information;
resource requests;
communication history; and
information about interactions with our emails or content.
8. Technical and usage information
Depending on the systems and services in use, we may collect information such as:
IP address;
browser type;
device information;
website usage information;
page interactions;
form interactions;
email interaction information;
referral source; and
analytics or cookie information.
Where cookies or similar technologies require consent under applicable law, we will use an appropriate consent mechanism.
9. How we collect information
We may collect personal information:
directly from you;
through websites, forms and questionnaires;
through booking systems;
through coaching or mentoring sessions;
through email, messaging and other communications;
through payment providers;
through CRM and marketing systems;
through website and analytics technologies;
from an organisation purchasing or arranging services for you;
from a person referring or introducing you, where appropriate; and
from other lawful sources.
Where another person or organisation provides information about you, we will handle that information in accordance with applicable data-protection requirements.
10. How we use your information
We may use personal information to:
respond to enquiries;
provide information about services;
take steps before entering into a contract;
manage bookings;
deliver coaching, mentoring, strategy and related services;
maintain appropriate continuity across an ongoing professional relationship;
prepare for sessions;
remember relevant context;
review goals, priorities and agreed actions;
provide follow-up information;
prepare or check summaries or action notes;
communicate with Clients;
manage recurring services and subscriptions;
administer payments;
manage failed or overdue payments;
provide lead magnets, resources and requested materials;
administer mailing lists;
send marketing where permitted;
keep appropriate business and Client records;
undertake reflective practice;
undertake appropriate professional supervision;
improve our services, systems, content and customer experience;
maintain security;
prevent or respond to fraud or misuse;
establish, exercise or defend legal rights;
comply with legal, regulatory, tax, accounting and business obligations; and
operate and improve our business.
11. Our lawful bases for processing
The lawful basis we rely on depends on the information and the purpose for which it is used.
We may rely on the following bases.
Contract
We may process personal information where necessary to:
provide a service you have purchased;
manage a coaching or mentoring relationship;
administer bookings;
communicate about delivery of the service;
manage agreed payments; or
perform our contractual obligations.
Steps before entering into a contract
We may process information where necessary to respond to matters such as:
an enquiry;
a request for information about working together;
a pre-service form; or
discussions about a potential engagement.
Legal obligation
We may process information where necessary to comply with legal requirements, including appropriate:
tax;
accounting;
company;
regulatory; or
other legal obligations.
Legitimate interests
We may process information where necessary for legitimate business purposes and where those interests are not overridden by the rights and interests of the individuals concerned.
Depending on the circumstances, this may include:
managing and improving our business;
maintaining appropriate records;
service administration;
protecting our systems;
preventing fraud or misuse;
understanding service performance;
managing professional relationships;
maintaining appropriate continuity;
establishing, exercising or defending legal rights; and
improving services and customer experience.
Where we rely on legitimate interests, we consider the necessity and proportionality of the processing and its potential effect on the individuals concerned.
Consent
We may rely on consent where you have made a genuine choice about a particular use of information.
Examples may include:
certain marketing communications;
optional uses of information;
specific recordings where consent is required; or
particular processing of special-category personal data.
Where processing relies on consent, you may withdraw that consent at any time.
Withdrawal does not make earlier lawful processing unlawful.
12. Special-category personal data
Some types of personal information receive additional protection under data-protection law.
These include certain information concerning:
racial or ethnic origin;
political opinions;
religious or philosophical beliefs;
trade-union membership;
genetic data;
biometric data used for unique identification;
health;
sex life; and
sexual orientation.
We do not seek to collect special-category personal data unnecessarily.
Where special-category information is intentionally recorded, retained or otherwise processed for a particular purpose, we will identify:
an appropriate lawful basis for the processing; and
an applicable additional condition permitting the processing of that special-category information.
Depending on the particular circumstances and purpose, this may include the Client’s explicit consent.
For example, where a Client wants Marie to remember a health condition, disability, neurodivergence or other relevant matter so that future coaching can be adapted or delivered with that information in mind, Marie may ask whether the Client expressly agrees to that information being recorded for that purpose.
Where explicit consent is relied upon:
the purpose of the proposed record or use will be identified;
the Client may decline;
the Client may later withdraw that consent; and
withdrawal does not make earlier lawful processing unlawful.
Depending on the circumstances, withdrawal may affect our ability to retain or continue using the particular information concerned.
We aim to minimise the amount and detail of sensitive information retained and will not ordinarily record unnecessary intimate detail where a more general note is sufficient for the coaching purpose.
13. Coaching notes and professional records
Where you receive coaching, mentoring or related services, Marie Cowgill may take and retain reasonable handwritten or electronic professional notes.
Notes may be created:
during a session;
immediately after a session;
between sessions;
when preparing for a future session; or
when reviewing the coaching relationship.
Notes may be used for purposes including:
maintaining continuity;
remembering relevant context;
reviewing goals and actions;
preparing for future sessions;
follow-up;
reflective practice;
professional development;
appropriate supervision;
administration;
quality improvement;
record-keeping; and
protecting or exercising legal rights.
Professional coaching notes:
may be selective;
are not necessarily intended to be a complete transcript;
may distinguish between factual information and professional reflection where appropriate; and
will aim to avoid unnecessary personal detail.
Where sensitive information is mentioned but not reasonably necessary to retain, the note may record only a general matter or omit the detail altogether.
14. Reflective practice and professional supervision
As part of responsible professional practice, coaching work may be considered for:
reflective practice;
professional development; or
appropriate coaching supervision.
Where reasonably practicable, we will seek to:
minimise unnecessary disclosure;
anonymise or pseudonymise information;
avoid identifying an individual where identification is unnecessary; and
use supervisors or professionals subject to appropriate confidentiality expectations.
We do not rely on this section as permission to publish identifiable Client stories, testimonials or case studies for marketing purposes.
Separate appropriate permission will be obtained where required.
15. AI-assisted and digital tools
We may use appropriate digital, software-assisted or artificial-intelligence-enabled tools to support the delivery, administration and improvement of services.
Depending on the tool and purpose, this may include:
structuring notes;
organising non-verbatim notes;
summarising themes;
identifying actions or goals;
drafting follow-up summaries;
preparing action lists;
supporting continuity between sessions;
drafting session-related communications;
administrative support;
reflective review; and
organising or searching appropriate business records.
The use of AI-assisted tools does not change our underlying approach to data minimisation.
We do not treat the availability of an AI tool as a reason to collect or retain more Client information than is reasonably necessary.
Where reasonably practicable, we may:
minimise the information provided to a tool;
remove unnecessary identifiers;
use a generalised description rather than unnecessary sensitive detail;
use a relevant extract rather than an entire record; or
avoid using particular information where it is not needed for the task.
Where AI-assisted tools process personal information:
applicable data-protection requirements continue to apply;
we will consider the purpose and lawful basis for the processing;
we will take reasonable steps when selecting relevant providers;
AI-generated output may be reviewed, edited, rejected or corrected;
AI output is not treated as automatically accurate; and
appropriate human judgement remains part of the service.
Where we have a reasonable contractual or technical choice, we do not intentionally submit confidential Client information for the purpose of training a publicly available general-purpose AI model.
This does not prevent ordinary processing by a service provider engaged under appropriate arrangements and in accordance with applicable data-protection obligations.
16. Recording, transcription and AI meeting assistants
We do not treat engagement with our services as blanket permission to secretly record coaching sessions.
Where we propose to use:
audio recording;
video recording;
automated full-session transcription;
an AI meeting assistant capturing substantially the whole conversation; or
comparable technology,
we will provide appropriate information and obtain any additional consent or permission required by applicable law.
The use of a digital or AI-assisted tool for limited note organisation, summary support or post-session administration is not necessarily the same as recording or transcribing an entire session.
17. Session summaries and action notes
We may, but are not obliged to, provide:
session summaries;
agreed-action lists;
goal summaries;
reflection prompts;
priorities; or
other follow-up materials.
These may be prepared with appropriate digital or AI-assisted support.
Where reasonably practicable, summaries will focus on information useful for the coaching purpose rather than reproducing unnecessary personal detail.
A summary is a supportive working aid rather than a guaranteed verbatim transcript.
You should tell us promptly if a summary materially misstates an important:
agreed action;
goal;
factual matter; or
other relevant point.
18. Service communications
Where you book, purchase or receive a service, we may send communications reasonably needed to administer and deliver that service.
These may include:
confirmations;
reminders;
Microsoft Teams links;
calendar invitations;
rescheduling information;
cancellation information;
payment information;
Direct Debit information;
onboarding information;
service updates;
follow-up communications; and
information relevant to an ongoing Client relationship.
These service communications are separate from optional marketing communications.
19. Marketing communications
We may send marketing emails, newsletters, resources and updates where:
you have consented;
applicable law otherwise permits us to contact you; or
another lawful basis applies to the specific communication.
You may unsubscribe from marketing emails at any time using the unsubscribe link provided or by contacting:
Unsubscribing from marketing does not prevent us from sending necessary service or contractual communications.
20. Payments and Direct Debits
Payments may be processed through third-party providers including:
Stripe;
GoCardless; and
other payment systems notified where relevant.
Recurring payments or Direct Debit mandates may be administered through GoCardless or another provider.
We may receive information such as:
payment status;
mandate status;
transaction references;
failed-payment information;
cancellation status; and
other information reasonably required to administer the service.
We do not ordinarily receive or store full payment-card details or full online-banking credentials.
Payment providers process information under their own applicable privacy terms as well as any relevant arrangements with us.
21. Third-party service providers
We use service providers to help operate our business and deliver services.
These may include providers of:
CRM systems;
forms;
booking systems;
email communications;
workflow automation;
cloud storage;
email and productivity services;
video conferencing;
calendar services;
payment processing;
Direct Debit administration;
website hosting;
analytics;
marketing;
document and electronic-signature systems;
AI-assisted and digital productivity tools; and
professional services.
Providers currently or potentially used in relevant parts of our operations include:
GoHighLevel / LeadConnector for CRM, forms, booking pages, workflows, communications and related functions;
Microsoft 365, Outlook and Microsoft Teams for email, calendar, storage, productivity and online sessions;
Stripe for relevant payment processing;
GoCardless for Direct Debit and recurring-payment administration; and
website, hosting, analytics, document, marketing and other technology providers where relevant.
Not every provider processes information about every individual.
We take reasonable steps appropriate to the circumstances when selecting providers that process personal information.
22. Corporate sponsors and third-party payers
Sometimes an organisation or another person may purchase or fund coaching for a Participant.
Where the payer and coaching Participant are different people, we may process information necessary to:
administer the engagement;
manage payment;
manage scheduling;
confirm attendance;
confirm whether an engagement remains active; and
manage any specifically agreed reporting arrangement.
We do not ordinarily disclose:
substantive coaching content;
professional coaching notes;
personal reflections; or
confidential session information
to an employer, sponsor or third-party payer without the Participant’s permission.
Exceptions may apply where:
disclosure is required by law;
disclosure is necessary to establish, exercise or defend legal rights;
another applicable confidentiality exception applies; or
a specific reporting arrangement has been expressly agreed in advance.
Where a specific reporting arrangement exists, the nature and scope of information to be shared should be identified in advance.
23. International clients and international processing
We may work with Clients located outside the United Kingdom and use technology providers operating internationally.
Personal information may therefore be processed, stored or accessed in countries outside the United Kingdom.
Where international-transfer rules apply, we will take steps required by applicable data-protection law.
Depending on the circumstances, this may include reliance on:
UK adequacy regulations;
recognised contractual safeguards;
the UK International Data Transfer Agreement;
an applicable UK Addendum;
another legally recognised transfer mechanism; or
a permitted exception where genuinely applicable.
Where required, we will also consider additional safeguards and transfer risks.
24. How long we keep information
We keep personal information only for as long as reasonably necessary for the relevant purpose.
Different information may be kept for different periods.
When deciding how long to retain information, we may consider:
the nature of the relationship;
the purpose for which the information was collected;
whether the information remains relevant;
contractual requirements;
legal obligations;
tax and accounting requirements;
professional record-keeping;
dispute and limitation periods;
protection of legal rights;
data minimisation; and
whether continued retention remains reasonably necessary.
Enquiries
Enquiry records may be kept for a reasonable period to:
respond;
follow up appropriately; and
maintain relevant business records.
Client and coaching records
Client relationship records, agreements, material communications and appropriate coaching records may be retained for a reasonable period after the relationship ends where necessary for purposes such as:
continuity;
professional record-keeping;
dispute management;
legal obligations; and
protection of legal rights.
Sensitive information
Where sensitive or special-category information has been intentionally retained for a particular purpose, we will consider whether it remains necessary for that purpose.
We do not intend to retain sensitive information indefinitely merely because it was once relevant.
Financial and tax records
Relevant payment, invoice and transaction records may be retained for periods required by:
tax;
accounting; and
other legal obligations.
Marketing information
Marketing contact information may be retained until:
you unsubscribe;
you withdraw relevant consent;
the information is no longer reasonably required; or
we otherwise determine it should be deleted.
We may retain limited suppression information where necessary to respect an unsubscribe or do-not-contact request.
We periodically review retention where appropriate.
25. How we protect information
We take reasonable technical and organisational steps to protect personal information.
Depending on the circumstances, measures may include:
reputable business systems;
password protection;
access controls;
restricted account access;
authentication controls;
appropriate provider selection;
secure cloud systems;
software updates; and
data minimisation.
No online or electronic system can be guaranteed completely secure.
26. Your data-protection rights
Depending on the circumstances and applicable law, you may have rights including the right to:
be informed about how your personal information is used;
access personal information held about you;
ask for inaccurate information to be corrected;
ask for deletion of information in certain circumstances;
ask for processing to be restricted in certain circumstances;
object to certain processing;
receive certain information in a portable format;
withdraw consent where processing relies on consent; and
complain to the Information Commissioner’s Office.
These rights are not absolute and may depend on:
the circumstances;
the type of information;
the purpose of processing; and
the lawful basis involved.
To make a request, contact:
We may need to verify identity before acting on certain requests.
27. Withdrawal of consent
Where we rely on your consent for a particular use of information, you may withdraw that consent.
This includes, where relevant, consent concerning a specifically identified sensitive fact recorded for a particular coaching purpose.
You can contact:
Withdrawal of consent:
does not make earlier lawful processing unlawful;
may mean that we stop using the relevant information for the consent-based purpose; and
may affect an aspect of a service where that aspect genuinely depends on the information concerned.
There may be limited circumstances where particular information must continue to be retained or processed on another lawful basis, for example because of a legal obligation or the establishment, exercise or defence of legal rights.
28. Automated decision-making
We do not currently use solely automated decision-making that produces legal effects or similarly significant effects on individuals in relation to our ordinary coaching and mentoring services.
If this changes, we will provide relevant information and comply with applicable requirements.
29. Complaints
If you are concerned about how we use or protect your personal information, or believe that we have not complied with applicable data-protection law, you can make a data-protection complaint by contacting:
Please include enough information for us to understand the nature of your complaint and investigate it appropriately.
We will acknowledge receipt of a data-protection complaint within 30 days.
We will take appropriate steps to investigate the complaint without undue delay, make reasonable enquiries where necessary, keep you informed as appropriate and communicate the outcome of our investigation once it is complete.
If you remain dissatisfied, you also have the right to raise your concern with the Information Commissioner’s Office.
Information about data-protection complaints and rights is available through the ICO.
30. Changes to this Privacy Policy
We may update this Privacy Policy from time to time, including where:
services change;
technology changes;
service providers change;
legal requirements change; or
our use of personal information changes.
The latest version will be made available through our website, booking pages or another appropriate location.
Where required by law, we will provide additional information or notice before materially different processing begins.