Privacy Policy

Last Updated: September 16th, 2026

This website (www.jessiegretener.com) is operated by Delvvy LTD ("we", "us", or "our"). Delvvy LTD is a limited company registered in England and Wales (Company number: 15760294). Delvvy LTD is registered with the Information Commissioner's Office (Registration number: ZB802272). Jessie Gretener trades through Delvvy LTD.

We are committed to protecting your privacy. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, the legal bases we rely on, who we may share it with, and what rights you have. It should be read alongside our Cookies Policy.

By using this website, you acknowledge that your personal data will be processed as described in this policy.

Data Controller and Company Information

Delvvy LTD is the data controller responsible for your personal data collected through this website. If you have any questions about this policy or how we handle your data, or to exercise your legal rights, you can contact us at:

  • Registered Address: 167-169 Great Portland Street, 5th Floor, London, England, W1W 5PF

  • Email: hello@delvvy.com

What are Data Subjects?

Data subjects are identified or identifiable individuals to whom personal data relates. In this policy, "you" or "data subject" means an individual whose personal data we process. This may include individuals who visit our website, contact us, book a consultation or service, purchase or participate in our services, or otherwise engage with us.

Data subjects have rights under applicable data protection law, including rights to access their personal data, request rectification, object to certain processing, restrict processing, and request erasure in certain circumstances.

What Personal Data We Collect

Depending on how you interact with the website, we may collect:

  • Contact details: such as your name and email address, when you fill in a contact form, subscribe to a newsletter, make an enquiry, or otherwise get in touch.

  • Correspondence: the content of any messages you send us.

  • Booking information: if you book a consultation, session, or event through the website, information you provide as part of that booking.

  • Payment information: if you make a purchase, payment details are processed directly by our payment processor; we do not store full card details ourselves.

  • Technical data: such as your IP address, browser type, device information, and pages visited, collected automatically via cookies and analytics tools (see our Cookies Policy).

  • Usage data: information about how you use the website, such as which pages you view and how long you spend on them.

  • Marketing preferences: such as whether you have opted in or out of receiving marketing communications from us.

  • Information you voluntarily provide in connection with our services: for example, information you choose to provide when participating in a consultation, coaching session, workshop, or other service.

Special Category Data

The UK GDPR designates certain personal data as "special category data," which is more sensitive and requires extra protection. Special category data may only be processed where we have both a lawful basis under Article 6 of the UK GDPR and an applicable condition under Article 9 of the UK GDPR and, where required, the Data Protection Act 2018.

Special category data includes:

  • Racial or ethnic origin

  • Political opinions

  • Religious or philosophical beliefs

  • Trade union membership

  • Genetic data

  • Biometric data (used for identification)

  • Health information

  • Sex life information

  • Sexual orientation

Explicit consent is one possible condition for processing special category data, but it is not the only one. Where we rely on explicit consent, that consent will be specific, informed, affirmative and capable of being withdrawn.

We do not knowingly collect any special category data through general use of the website. Where our services involve you voluntarily sharing sensitive personal information with us directly - for example, in a message, during a coaching session or at a workshop - we only process that information for the purpose you shared it, with appropriate safeguards, and only where we have identified an applicable lawful basis and special category condition under data protection law. We will not use such information for unrelated purposes without an appropriate legal basis.

Recording of Sessions

If any consultation, coaching session, or workshop is recorded (whether audio, video, or written notes beyond ordinary session notes), we will tell you before the session takes place and will only record with your consent. Recordings will only be used for the purpose you consented to and will be stored and deleted in line with this policy.

Artificial Intelligence Tools

We do not currently use any AI tools (such as chatbots, AI-assisted drafting, or AI-based analysis) to process personal data you provide to us, including enquiries, session notes, or booking information. If this changes in the future, we will update this policy to explain what data is involved, which tool is used, and the safeguards in place, before doing so.

How We Use Your Data

We use your personal data to:

  • Respond to your enquiries and correspondence.

  • Provide, manage, and confirm any bookings or services you request.

  • Send you newsletters or marketing communications where you have given consent, or where otherwise permitted by applicable law, including where the requirements of the "soft opt-in" exception for similar products or services are met.

  • Operate, maintain, and improve the website.

  • Analyse how visitors use the website so we can improve content and user experience.

  • Comply with our legal and regulatory obligations.

  • Protect the security of our website, systems, services and users and prevent fraud or misuse.

  • Publish testimonials, quotes, or case studies about our services, but only where you have separately and specifically consented to this.

Our Legal Basis for Processing

Under UK GDPR, we rely on the following legal bases to process your personal data:

  • Consent: for example, when you opt in to receive marketing emails, accept non-essential cookies, or agree to a session recording or the publication of a testimonial.

  • Contract: where processing is necessary to provide a service or booking you have requested or to take steps prior to entering into a contract.

  • Legitimate interests: for example, to understand how the website is used and to keep it secure, provided this does not override your rights and interests.

  • Legal obligation: where we are required to process data to comply with the law.

Where we rely on legitimate interests, we will consider the impact of the processing on your rights and interests and only rely on this basis where our interests are not overridden by your rights and freedoms.

Our legitimate interests may include operating and improving our website and services, communicating with customers and prospective customers where permitted, maintaining the security of our systems and services, preventing fraud or misuse, and managing and administering our business.

Where we process special category data, we will also identify and rely on an applicable Article 9 condition, as required by law.

Who We Share Your Data With

We do not sell your personal data. We may share it with:

  • Service providers who help us run the website and our business, such as hosting platforms, scheduling platforms, email marketing platforms, and payment processors. We use trusted data processors to collect, process, and store personal data. Each of the providers acts on our instructions and are bound by applicable data protection obligations.

  • Professional advisers, such as accountants or lawyers, where necessary.

  • Regulators or authorities, where required by law.

  • Other third parties where necessary to provide a service you have requested, or where you have otherwise asked or authorised us to share your information.

Some of these providers may be located outside the UK or EEA. Where this is the case, we ensure appropriate safeguards are in place in accordance with applicable data protection law. Where required, this may include an adequacy decision or appropriate contractual safeguards.

Third-Party Links and Content

This website may contain links to, or embedded content from, third-party websites or platforms. If you click through to or interact with these, that platform's own privacy policy applies, not this one. We are not responsible for the privacy practices of any third-party website or platform.

How Long We Keep Your Data

We keep personal data only for as long as necessary for the purposes it was collected, including to satisfy any legal, accounting, or reporting requirements. Retention periods vary depending on the type of data and the purpose of processing. For example, we may retain financial and transaction records for the period required by applicable tax and accounting requirements.

Where appropriate, we will periodically review the personal data we hold and securely delete or anonymise information that is no longer required.

Your Rights

Under UK GDPR, you have the right to:

  • Access the personal data we hold about you.

  • Rectify inaccurate or incomplete data.

  • Erase your data in certain circumstances.

  • Restrict how we use your data.

  • Object to processing based on legitimate interests and to direct marketing.

  • Data portability, to receive your data in a structured, machine-readable format.

  • Withdraw consent at any time, where processing is based on consent.

You may have the right to object to certain types of processing and, in some circumstances, to rights relating to automated decision-making and profiling, where applicable.

To exercise any of these rights, contact us at hello@delvvy.com. We may need to verify your identity before responding to your request. We will respond within one month, as required by law, subject to any applicable legal extensions or exemptions.

If you are unhappy with how we have handled your personal data, you also have the right to complain to the UK's data protection regulator:

  • Information Commissioner's Office (ICO) ico.org.uk | Helpline: 0303 123 1113

Data Breaches

We take appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

In compliance with the UK GDPR, where we become aware of a personal data breach that is likely to result in a risk to individuals' rights and freedoms, we will notify the Information Commissioner's Office without undue delay and, where feasible, within 72 hours of becoming aware of the breach.

We will assess each personal data breach to determine whether notification to the ICO is legally required. Not every personal data breach is required to be reported to the ICO.

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will inform affected individuals without undue delay where required by law.

Children's Privacy

This website is not directed at children, and we do not knowingly collect personal data from anyone under the age of 18. If you believe a child has provided us with personal data, please contact us and we will take steps to delete it.

If you are under 18, please do not provide us with personal information or use our services without the involvement and consent of a parent or guardian where required.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. Any changes will be posted on this page with an updated "Last updated" date. We encourage you to review this policy periodically.

Contact

If you have questions about this policy, you can contact us at:

  • Registered Address: 167-169 Great Portland Street, 5th Floor, London, England, W1W 5PF

  • Email: hello@delvvy.com