Privacy Policy

1. Introduction

North Willow Gate Consulting Ltd. ("we", "us", "our", or "North Willow Gate") is committed to protecting the privacy and confidentiality of all individuals who engage with our services, visit our website, or interact with our team. This Privacy Policy explains how we collect, use, store, and protect your personal data in accordance with applicable Ugandan law, including the Data Protection and Privacy Act (2019), and in alignment with internationally recognised best practice.

This Policy applies to all individuals who: (a) use our website at northwillowgate.info; (b) engage with our coaching, consulting, or facilitation services; (c) subscribe to our newsletter or communications; (d) apply for employment or partnership with us; or (e) otherwise share personal information with North Willow Gate Consulting Ltd.

By engaging with our services or using our website, you acknowledge and consent to the practices described in this Privacy Policy.

2. Information We Collect

2.1 Information You Provide Directly

We collect information you provide when you:

• Complete and submit our contact or enquiry form
• Register for a coaching programme, workshop, or event
• Subscribe to our newsletter or blog updates
• Communicate with us by email, phone, or in person
• Apply for employment or a contractor role
• Complete assessments, surveys, or programme evaluations

This may include your name, email address, phone number, job title, organisation, and any information you choose to share about your professional situation, development goals, or personal circumstances.

2.2 Information Collected Automatically

When you visit our website, we may automatically collect certain technical information, including your IP address, browser type and version, pages visited, time and date of your visit, and referring URL. This information is collected using cookies and similar tracking technologies and is used for website analytics and security purposes.

2.3 Sensitive Information

In the context of coaching and development programmes, you may share information of a sensitive personal nature — including information about your health, relationships, family situation, or personal history. This information is handled with the highest level of confidentiality and is never shared without your explicit written consent. Please see Section 5 for our specific commitments regarding coaching confidentiality.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

• To respond to your enquiries and communicate with you about our services
• To design, deliver, and evaluate coaching and consulting programmes
• To send you newsletters, insights, and communications you have opted into
• To process programme applications and payments
• To maintain records required for our professional practice
• To improve our website, services, and client experience
• To comply with legal and regulatory obligations
• To conduct programme impact assessments and research (always anonymised)

We will never use your personal information for purposes not listed above without first obtaining your explicit consent.

4. Sharing and Disclosure

North Willow Gate does not sell, rent, or trade your personal information to third parties. We may share your information only in the following limited circumstances:

• With your employer/sponsor: If your coaching is sponsored by your employer, we may confirm your programme enrolment and provide agreed general progress updates — but never share session content without your consent.
• With trusted service providers: We use third-party tools for email communication, video conferencing, and payment processing. These providers are bound by confidentiality and data protection obligations.
• For legal compliance: We may disclose information if required by Ugandan law, court order, or regulatory authority.
• In aggregated, anonymised form: For research, reporting, and marketing purposes, we may use aggregated data that cannot identify any individual.

5. Coaching Confidentiality

Coaching confidentiality is the cornerstone of our practice. We are committed to the highest standards of professional confidentiality in all coaching and consulting relationships:

• Everything discussed in coaching sessions is confidential between the coach and client.
• We do not share session content, personal disclosures, or coaching notes with any third party — including sponsoring employers — without your explicit written consent.
• Exceptions to confidentiality apply only where legally required (e.g., a serious risk of harm to self or others) and even then, we will seek to inform you first wherever possible.
• Coaches keep session notes securely and these notes are not part of any employment, HR, or organisational record.

If you are in a sponsored coaching programme, the nature of our confidentiality commitment will be explained clearly in your coaching agreement before sessions begin.

6. Cookies and Tracking

Our website uses cookies to enhance your browsing experience. Cookies are small text files placed on your device. We use:

• Essential cookies: Required for the website to function correctly.
• Analytics cookies: To understand how visitors use our website (via anonymised data).
• Preference cookies: To remember your settings and preferences.

You can control or disable cookies through your browser settings. Please note that disabling cookies may affect the functionality of our website.

7. Data Retention

We retain personal information only as long as necessary for the purposes outlined in this Policy, or as required by law. Specifically:

• Client coaching records are retained for 7 years after the end of the engagement.
• Newsletter subscriber data is retained until you unsubscribe.
• Enquiry and contact form submissions are retained for 2 years.
• Financial records are retained for 7 years in compliance with Ugandan tax law.

When data is no longer needed, it is securely deleted or anonymised.

8. Your Rights

Under the Uganda Data Protection and Privacy Act (2019), you have the following rights regarding your personal data:

• Right of access: You may request a copy of the personal information we hold about you.
• Right to rectification: You may ask us to correct inaccurate or incomplete information.
• Right to erasure: In certain circumstances, you may request that we delete your personal data.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time.
• Right to object: You may object to certain types of processing, including direct marketing.
• Right to complain: You have the right to lodge a complaint with Uganda's Personal Data Protection Office.

To exercise any of these rights, please contact us at hello@northwillowgate.info. We will respond within 30 days.

9. Security

We implement appropriate technical and organisational security measures to protect your personal information from unauthorised access, disclosure, alteration, or destruction. These include encrypted communications, access controls, staff confidentiality training, and regular security reviews. While we take every reasonable precaution, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.

10. Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal obligations. When we make significant changes, we will notify you by email (if you are subscribed to our communications) and update the "Last Updated" date at the top of this page. We encourage you to review this Policy periodically.

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact our Data Protection Officer: