Open Meadow Deck Consulting Ltd ('we', 'our', 'us') is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and protect information we receive from visitors to our website and from clients of our coaching and consulting services. We are incorporated in Uganda (Company Reg. No. 80112345) and operate in compliance with Uganda's Data Protection and Privacy Act 2019.
1. Information We Collect
We collect the following categories of personal data in the course of operating our website and delivering our services:
- Contact details: Full name, email address, phone number, professional title, and organisation name.
- Website usage data: Pages visited, time on site, device type, browser type, and referring URLs — collected through analytics tools.
- Coaching intake information: Goals, career history, personal challenges, and coaching objectives. This category is treated as highly sensitive and afforded the highest level of protection we apply.
- Payment information: Billing details necessary for processing payments. These are handled exclusively by third-party payment processors and are never stored directly on our systems.
- Cookies and local storage data: Technical identifiers and preference data placed on your device during website use.
Note on sensitive coaching data: Information you share about personal challenges, career history, and coaching goals is treated with the strictest confidentiality under the ICF Code of Ethics and Uganda's Data Protection and Privacy Act 2019.
2. How We Collect Your Information
We collect personal data through the following channels:
- Our website contact and enquiry forms
- Email correspondence with you or your organisation
- Phone and WhatsApp enquiries
- Coaching intake questionnaires completed before or at the start of an engagement
- Virtual session platforms such as Zoom and Microsoft Teams (session metadata only — we do not record sessions without your explicit prior consent)
- Cookies and tracking technologies placed during your use of our website
3. How We Use Your Information
We use the personal data we collect for the following purposes:
- To deliver the coaching and consulting services you have requested
- To communicate with you about your engagement and respond to enquiries in a timely manner
- To send relevant updates and our newsletter — only with your explicit prior consent
- To improve our website experience and service quality through analysis of usage patterns
- To comply with legal and regulatory obligations under Ugandan law
- To generate anonymised and aggregated statistical reports in which no individual can be identified
We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects on you.
4. Legal Basis for Processing
Under the Uganda Data Protection and Privacy Act 2019, we rely on the following legal grounds for processing your personal data:
| Legal Basis | When We Rely On It |
|---|---|
| Consent | For marketing communications, newsletter subscriptions, and optional data collection beyond what is strictly necessary for service delivery. |
| Contract Performance | For delivering coaching and consulting services to paying clients — processing is necessary to perform our obligations under your signed Coaching Agreement. |
| Legitimate Interests | For improving our services, fraud prevention, and internal analytics — where our interests are not overridden by your rights and freedoms. |
| Legal Obligation | For retaining financial and client records as required by the Uganda Revenue Authority and other applicable legislation. |
5. Data Sharing
We do not sell, rent, or trade your personal data to any third party. We may share your data only in the following limited circumstances:
- ICF-accredited supervision: Anonymised case notes only, shared for quality assurance and professional coach supervision. No personally identifiable information is disclosed.
- Payment processors: Stanbic Bank and MTN Mobile Money, who operate under their own privacy policies and security standards.
- IT service providers: Cloud hosting and email system providers, who operate under written data processing agreements aligned with the Data Protection and Privacy Act 2019.
- Legal authorities: Where disclosure is required by a binding court order or other legal obligation under Ugandan law.
International transfers: We do not transfer your personal data outside Uganda without ensuring that adequate protection measures are in place, including appropriate contractual safeguards or equivalent protections.
6. Coaching Session Confidentiality
All coaching session content is strictly confidential. This obligation arises under both the ICF Code of Ethics and your Coaching Agreement with us. We will not disclose session content to any third party — including sponsoring employers or organisational funders — without your explicit written consent.
The only circumstances in which confidentiality may need to be broken are:
- (a) Imminent risk of serious harm — where there is a credible, immediate risk of serious harm to you or to another identifiable person.
- (b) Court order — where disclosure is compelled by a court order issued under Ugandan law.
Supervision: Our coaches engage in regular professional supervision as required by ICF standards. All supervision uses fully anonymised case material. No personally identifiable client information is shared in supervision settings.
7. Cookies
We use cookies and similar technologies on our website. The categories we use are as follows:
| Cookie Type | Purpose | Can Be Disabled? |
|---|---|---|
| Strictly Necessary | Session management and website security. Required for the site to function correctly. | No — always active |
| Analytics | Google Analytics — to understand visitor behaviour, popular content, and how to improve the website experience. | Yes — via browser settings or the Google Analytics opt-out tool |
| Preference | To remember your settings and preferences across visits to our site. | Yes — via browser settings |
You can manage or disable cookies through your browser settings at any time. Disabling analytics or preference cookies does not affect the core functionality of our website.
8. Data Retention
We retain personal data only for as long as is necessary for the purposes for which it was collected, and to satisfy our legal obligations:
| Data Type | Retention Period |
|---|---|
| Client files and coaching records | 7 years after engagement end (Uganda Revenue Authority requirements) |
| Coaching session notes | 5 years after engagement end |
| Marketing opt-in records | Until you unsubscribe or withdraw consent |
| Website analytics data | 26 months (Google Analytics default) |
| Job applicant data | 12 months unless you request earlier deletion |
After the applicable retention period, personal data is securely deleted or fully anonymised so that it can no longer be attributed to any individual.
9. Your Rights Under the Data Protection and Privacy Act 2019
Under Uganda's Data Protection and Privacy Act 2019, you have the following rights in relation to your personal data:
Right of Access
Request and receive a copy of the personal data we hold about you.
Right to Rectification
Request correction of inaccurate or incomplete personal data we hold.
Right to Erasure
Request deletion of your data, subject to applicable legal retention obligations.
Right to Restrict
Request restriction of processing of your personal data in certain circumstances.
Right to Object
Object to certain types of processing, including direct marketing communications.
Data Portability
Receive your personal data in a structured, commonly used, machine-readable format.
To exercise any of these rights, email hello@openmeadowdeck.info with the subject line "Data Rights Request". We will acknowledge your request and respond substantively within 30 days.
10. Data Security
We take the security of your personal data seriously and implement the following technical and organisational safeguards:
- TLS/SSL encryption for all personal data in transit between your device and our systems
- Password-protected access controls with multi-factor authentication required for all staff who access personal data
- Annual security review conducted by qualified IT professionals to assess vulnerabilities and compliance with the Data Protection and Privacy Act 2019
- Staff training on data protection obligations, best practices, and incident response
- Documented incident response plan including a 72-hour notification obligation to the relevant authority and affected data subjects for any reportable data breach
While we implement strong safeguards, no digital system can be guaranteed completely secure. We encourage you to use updated devices, secure networks, and strong passwords when communicating with us online.
11. Children's Privacy
Our services are intended solely for professional adults and organisations. They are not directed at individuals under 18 years of age. We do not knowingly collect, store, or process personal data relating to minors.
If you believe a minor has submitted personal data to us, please contact us immediately at hello@openmeadowdeck.info. We will promptly delete any such information from our systems.
12. Third-Party Links
Our website may contain links to external websites and resources including the International Coaching Federation (ICF), the Private Sector Foundation Uganda (PSFU), and partner organisations. These links are provided for your convenience and information only.
We are not responsible for the privacy practices, content, or security of any third-party website. The inclusion of a link does not imply our endorsement. We encourage you to review the privacy policy of any third-party website before providing your personal data to them.
13. Changes to This Policy
We may update this Privacy Policy periodically to reflect changes in our practices, applicable law, or regulatory guidance. We will communicate material changes in the following ways:
- By email notification to all active clients
- By displaying a prominent notice on our website
The date of the most recent revision is shown at the top of this policy. Your continued use of our services after changes have been published constitutes your acceptance of the updated Privacy Policy. We encourage you to review this policy periodically.
14. Contact the Data Controller
Open Meadow Deck Consulting Ltd is the data controller responsible for your personal data. For any privacy-related enquiry, rights request, or complaint, please contact us using the details below:
Open Meadow Deck Consulting Ltd
Data Controller — Reg. No. 80112345
Email: hello@openmeadowdeck.info
Phone / WhatsApp: +256 700 123 456
Address: Plot 14 Wampewo Avenue, Kampala, Uganda
Please use the subject line "Privacy Enquiry" so we can direct your message to the right person promptly.
We aim to respond to all data-related enquiries within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with the relevant supervisory authority under the Uganda Data Protection and Privacy Act 2019.