Privacy Policy

Who we are

This website and the services offered through it are operated by AMN Calibrate Ltd, trading as David Fleming / TheDavidFleming.com.

Company number: 15494246
Registered address: 1 Magpie Farm, Appledore, Ashford, Kent TN26 2BF, United Kingdom
Email: [email protected]

For the purposes of UK data protection law, AMN Calibrate Ltd is the data controller unless otherwise stated.

Scope of this policy

This Privacy Policy applies when you interact with:

• TheDavidFleming.com;
• the Practitioner Clarity Assessment;
• RHM training programmes and live courses;
• The Frontier;
• Clarity Map and Clarity Snapshot;
• masterclasses, webinars, consultations and events;
• forms, applications, waitlists and email communications;
• payment and checkout pages;
• related websites, subdomains and online tools.

Personal data we may collect

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

• your name, email address, telephone number and other contact details;
• information submitted through forms, applications and waitlists;
• information you provide during training, consultations or online tools;
• booking, order, payment and transaction information;
• communications between you and us;
• marketing preferences and consent records;
• technical information such as IP address, browser type, device information, referring URL and page activity;
• advertising and referral identifiers, including Meta browser and click identifiers;
• registration, checkout and purchase activity.

The Practitioner Clarity Assessment

We do not intentionally request special category information unless it is necessary for a clearly stated purpose and an appropriate lawful basis applies.

Please do not submit confidential medical information or information about another person unless we specifically ask you to do so and it is appropriate to provide it.

How we use personal data

We may use personal information to:

• provide training, assessments, products, consultations and online tools;
• produce and deliver Practitioner Clarity Assessment results;
• provide profile-relevant follow-up after an assessment;
• process bookings, applications, registrations and payments;
• administer RHM courses and related practitioner services;
• provide customer support;
• send service-related communications;
• send marketing communications where permitted;
• improve our websites, products, educational content and systems;
• measure website and advertising campaign performance;
• understand which campaigns and content lead to registrations and assessment completions;
• create advertising and remarketing audiences where permitted;
• prevent fraud and protect our services;
• comply with legal, accounting and regulatory obligations.

Lawful bases for processing

Depending on the circumstances, we process personal information under one or more of the following lawful bases:

• Contract — where processing is necessary to provide a service, course, product or fulfil a purchase.
• Consent — including non-essential cookies, advertising technologies and marketing communications where consent is required.
• Legitimate interests — including operating, improving, protecting and measuring our services, responding to a request you have made and providing relevant follow-up, provided those interests are not overridden by your rights.
• Legal obligation — where processing is required to comply with applicable law.

Practitioner Clarity Assessment

We use your assessment information to produce and send your result, provide relevant follow-up and measure how practitioners arrive at and use the assessment.

Our lawful basis for producing and sending the result and related assessment follow-up is our legitimate interest in responding to your request and operating the assessment service.

Where you separately choose to receive ongoing essays, marketing or promotional communications, we rely on the consent you provide through the relevant opt-in.

Where consent is the lawful basis, you may withdraw it at any time.

Cookies and similar technologies

We use essential cookies for functions such as security, session management and operation of the website.

We also use non-essential cookies and similar technologies for advertising measurement and related purposes where you have consented.

Non-essential advertising technologies are not activated until the relevant consent is provided through our cookie banner.

You may reject non-essential cookies and change your preferences later.

Our consent-management tools may record your consent decision, consent identifier, date, time and selected cookie categories.

Tracking pixels, tags and scripts may be subject to the Privacy and Electronic Communications Regulations and UK GDPR requirements.

Meta Pixel and advertising measurement

With your consent, we use the Meta Pixel and related advertising measurement services provided by:

Meta Platforms Ireland Limited
Merrion Road
Dublin 4
D04 X2K5
Ireland

The Meta Pixel may help us:

• understand how visitors interact with our websites;
• measure the performance of advertising campaigns;
• record actions such as page visits, starting or completing the Practitioner Clarity Assessment, registrations, checkouts and purchases;
• create Custom Audiences for remarketing where permitted;
• create similar or Lookalike Audiences where permitted;
• avoid showing certain advertisements to people who have already completed a relevant action.

Depending on your interaction with our services, information associated with Meta measurement may include:

• pages viewed;
• advertising event names;
• registrations and conversion events;
• checkout or purchase events where relevant;
• transaction value and currency where relevant;
• product or service identifiers where relevant;
• IP address, browser and device information;
• Meta browser or click identifiers;
• hashed contact information where server-side conversion tracking is used.

Meta may process information received through its services under its own privacy terms and may act as an independent controller for certain processing activities.

You may withdraw or change your advertising consent at any time using the Cookie settings control on our website.

AI-based and automated tools

Some of our online tools may use automated or AI-assisted technology to generate a response, report, analysis or other output from information you provide.

Depending on the tool, information may be processed by third-party AI, hosting or infrastructure providers acting on our behalf.

Additional product-specific information may be provided where a particular tool operates differently from this policy.

You should not submit confidential medical information, sensitive personal data or information about another person unless specifically requested and legally appropriate.

AI-generated or automated outputs may contain errors and should not be treated as medical, psychological, legal or financial advice.

Payments and Merchant of Record services

Payments may be processed by Stripe or another payment or Merchant of Record provider.

Those providers may process information including:

• billing details;
• transaction information;
• payment method information;
• fraud-prevention data;
• tax and invoicing information.

Where a Merchant of Record is used, that provider may act as an independent controller for parts of the payment, tax, fraud and compliance process.

We do not normally receive or store your full payment-card details.

Service providers and data recipients

We may share personal information with trusted service providers where reasonably necessary to operate our services, including:

• Meta Platforms Ireland Limited — advertising measurement, conversion tracking, remarketing and advertising audiences;
• GoHighLevel / LeadConnector — CRM, forms, websites, workflows, contact records and communications;
• CookieYes — cookie-consent management and consent records;
• Cloudflare and other infrastructure providers — website hosting, application delivery, database and security infrastructure where used;
• Stripe and relevant Merchant of Record providers — payment, fraud, tax and transaction processing;
• email and communications providers;
• website hosting, cloud infrastructure and security providers;
• AI technology providers used to operate relevant online tools;
• professional advisers, accountants and legal advisers;
• regulators, courts or public authorities where disclosure is required by law.

We do not sell your personal data.

International data transfers

Some of the service providers we use may process personal information outside the United Kingdom or European Economic Area.

Where required, appropriate safeguards are used for international data transfers, which may include applicable adequacy regulations, recognised transfer frameworks or approved contractual protections.

Data retention

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and for applicable legal, accounting, tax, dispute-resolution and security requirements.

Practitioner Clarity Assessment

Other retention periods may include:

• enquiry and waitlist information — normally for up to 24 months where it is no longer required for an active relationship;
• customer, transaction and accounting records — for the period required by applicable tax and accounting law;
• marketing records — until consent is withdrawn, an objection is received or the information is no longer reasonably required;
• consent records — for as long as reasonably necessary to demonstrate compliance;
• online-tool or AI interaction data — according to the retention settings and operational requirements of the relevant service.

Marketing communications

We may send marketing communications where you have consented or where another lawful route permits us to do so.

Where the Practitioner Clarity Assessment contains a separate marketing or essay opt-in, that choice is independent of your request to receive your assessment result.

You may unsubscribe from marketing at any time using the unsubscribe link contained in an email or by contacting [email protected] .

Withdrawing marketing consent does not prevent us from sending service-related communications where those communications are necessary to provide something you requested or purchased.

Your data-protection rights

Depending on applicable law and the circumstances, you may have the right to:

• request access to personal information we hold about you;
• request correction of inaccurate information;
• request deletion of your information;
• request restriction of certain processing;
• object to certain processing;
• request data portability where applicable;
• withdraw consent where processing relies on consent;
• object to direct marketing;
• complain to a supervisory authority.

To exercise your rights, contact [email protected] .

You also have the right to complain to the UK Information Commissioner’s Office.

Security

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

No internet-based service can be guaranteed to be completely secure.

Changes to this policy

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

The latest version will be published on this page with an updated revision date.

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