Privacy Policy
Effective Date: 27 March 2026
RM Consulting ("we", "us", or "our") is operated by Robert McCubbin, based in Berlin, Germany. We are committed to protecting your privacy and handling your personal data responsibly and in compliance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR), the UK GDPR, the German Federal Data Protection Act (BDSG), and the California Consumer Privacy Act (CCPA/CPRA) where relevant.
This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit our website (robmccubbin.com or equivalent), book a discovery call, engage in executive coaching services, or otherwise interact with us.
By using our website or services, you agree to the practices described in this Policy.
### 1. Information We Collect
We may collect the following categories of personal information:
Personal Identifiers and Contact Data
Name, email address, phone number, mailing address, and professional title/role.
Professional and Coaching-Related Information
Details you share during discovery calls, coaching sessions, or correspondence (e.g., leadership challenges, goals, session notes). This may include sensitive information if you voluntarily disclose it (e.g., related to wellbeing or work-life balance).
Technical and Usage Data
IP address, browser type, device information, pages visited, and cookies or similar technologies (see Cookies section below).
Payment Information (if applicable)
Billing details processed securely via third-party payment providers. We do not store full credit card information ourselves.
We do not knowingly collect data from children under 18.
### 2. How We Use Your Information
We process your personal data for the following purposes:
- To respond to enquiries and schedule discovery calls or coaching sessions.
- To deliver executive coaching and leadership development services.
- To manage our client relationship, including invoicing and administrative purposes.
- To improve our website and services (e.g., analytics).
- To send occasional updates or newsletters (only with your consent or where we have a legitimate interest).
- To comply with legal obligations or defend legal claims.
### 3. Legal Basis for Processing (GDPR/UK GDPR)
We rely on one or more of the following lawful bases:
- Performance of a contract — when you engage us for coaching services or book a call.
- Legitimate interests — e.g., responding to enquiries, improving our services, or maintaining business records.
- Consent — where you explicitly agree (e.g., to marketing emails or certain cookies). You can withdraw consent at any time.
- Legal obligation — where required by law.
For any special category (sensitive) data you voluntarily share, we will process it only with your explicit consent or where necessary for the services.
### 4. Sharing Your Information
We do not sell your personal information.
We may share your data with:
- Trusted service providers (e.g., email providers, calendar/booking tools, secure video platforms, accountants, or hosting providers) who act as processors under strict data processing agreements.
- Professional advisers (lawyers, insurers) where necessary.
- Authorities, if required by law.
All third parties are contractually obligated to protect your data and process it only on our instructions.
### 5. International Data Transfers
As we are based in Germany (EU), data is primarily processed within the EU/EEA or UK (adequate jurisdiction). Where we use providers outside these areas (e.g., US-based tools), we ensure appropriate safeguards such as Standard Contractual Clauses (SCCs) or other GDPR-approved mechanisms.
### 6. Data Retention
We retain your personal data only as long as necessary for the purposes outlined above, or as required by law. Coaching session notes are typically kept for the duration of our engagement plus a reasonable period for follow-up or legal protection (usually up to 6–7 years for professional services records). Contact data for marketing is kept until you unsubscribe.
### 7. Your Rights
Under GDPR/UK GDPR you have the right to:
- Access your personal data
- Rectify inaccurate data
- Request erasure ("right to be forgotten")
- Restrict processing
- Object to processing (including for direct marketing)
- Data portability
- Withdraw consent at any time
Under CCPA/CPRA (for California residents), you have rights to:
- Know what personal information we collect, use, disclose, or sell/share
- Request deletion of your personal information
- Opt out of the sale or sharing of personal information (we do not sell data)
- Correct inaccurate personal information
- Non-discrimination for exercising your rights
To exercise any of these rights, please contact us at mccubbinra@gmail.com. We will respond within the legal timeframe (usually one month for GDPR; 45 days for CCPA, extendable where permitted).
You also have the right to lodge a complaint with your local data protection authority (in Germany: the Berlin Commissioner for Data Protection and Freedom of Information; in the UK: the Information Commissioner’s Office).
### 8. Cookies and Tracking Technologies
Our website may use essential cookies for functionality and analytics cookies (e.g., to understand visitor numbers). We will obtain your consent where required by law via a cookie banner. You can manage preferences through your browser settings or our consent tool.
We do not use cookies for targeted advertising that involves selling or sharing personal data.
### 9. Security
We implement reasonable technical and organisational measures to protect your personal data against unauthorised access, loss, or misuse. However, no system is completely secure, and we cannot guarantee absolute security.
### 10. Changes to This Privacy Policy
We may update this Policy from time to time. The "Effective Date" at the top will be revised. We encourage you to review it periodically. Continued use of our services after changes constitutes acceptance of the updated Policy.
### 11. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact:
Robert McCubbin
RM Consulting
Email: mccubbinra@gmail.com
Address: Berlin, Germany
For German/EU data subjects, our main establishment is in Germany.
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This version is clear, client-friendly, and suitable for a professional executive coaching site. It avoids over-promising while covering the key legal elements.