Privacy Policy
Last updated: March 2026
1. INTRODUCTION
This privacy notice explains how we collect, use, store, and protect your personal data when you interact with us, including through our website https://hummingbirdmentoring.com
By providing your personal data, you confirm that you are over 18 years of age.
Hummingbird Mentoring Ltd. is the data controller and is responsible for your personal data (referred to as “we”, “us”, or “our” in this policy).
Contact Details
Legal entity: Hummingbird Mentoring Ltd.
Data Controller: Jo-Anne Mac Millan
Email: support@hummingbirdmentoring.com
Postal address: 7 Marina Walk, Ballycuggaran, Killaloe, Co. Clare
It is important that the personal data we hold about you is accurate and up to date. Please notify us of any changes by emailing support@hummingbirdmentoring.com
2. WHAT DATA WE COLLECT, WHY WE COLLECT IT, AND OUR LAWFUL BASIS
Personal data means any information that can identify an individual. It does not include anonymised data.
We may process the following categories of personal data:
Customer / Client Data
This includes your name, title, billing address, email address, phone number, contact details, images or videos you choose to share, purchase details, and payment-related information.
Purpose: To deliver services you have purchased and maintain records.
Lawful basis: Performance of a contract and/or taking steps at your request prior to entering a contract.
Associate & Supplier Data
This includes names, contact details, billing details, and payment information.
Purpose: To manage supplier and professional relationships.
Lawful basis: Performance of a contract.
Coachee & Service Participant Data
This may include your name, email address, telephone number, signed agreements, reflections, questionnaires, or assessment outputs that are voluntarily shared during coaching, mentoring, or facilitation work.
Purpose: To deliver services and maintain appropriate professional records.
Lawful basis: Performance of a contract and legitimate interest in providing a high-quality, continuous service.
Session & Administrative Records Data
This may include session notes, action points, summaries, time records, and—only where explicitly agreed in advance—meeting recordings or transcripts.
Where recordings or transcriptions are used, they are created only with your explicit consent and for purposes such as continuity, clarity, and accurate record-keeping.
Lawful basis: Consent (where applicable), performance of a contract, and legitimate interests.
Communication Data
This includes emails, contact forms, messages, or other communications you send to us.
Purpose: Communication, record-keeping, and legal protection.
Lawful basis: Legitimate interests.
User & Technical Data
This includes data about how you use our websites and online services, such as IP address, browser type, page views, and navigation paths.
Purpose: Website administration, security, analytics, and improvement.
Lawful basis: Legitimate interests.
Marketing Data
This includes preferences relating to receiving communications from us.
Purpose: Sending relevant updates, newsletters, events, or offerings.
Lawful basis: Consent or legitimate interests.
3. USE OF DIGITAL, PLATFORM AND AI-ASSISTED TOOLS
We use carefully selected digital service providers to support the delivery of our services, administration, communication, and financial management.
These may include platforms and tools such as:
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Kajabi (website, memberships, digital platform)
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Stripe / Kajabi Payments (payment processing)
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QuickBooks (accounting)
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Kitchen.co (client portal for website clients)
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Cloudflare (website hosting infrastructure)
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Google Workspace (email and document storage)
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Scheduling platforms (e.g., TidyCal, where applicable)
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Social media platforms (e.g., LinkedIn, Instagram)
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YouTube
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Podcast hosting platforms
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Insight Timer
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AI-assisted tools for note-taking, transcription (with consent), drafting and administrative support
This list is indicative and may not be exhaustive.
Where AI-assisted tools are used:
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They support organisation, continuity, and administration.
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They do not replace professional judgement.
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They are not used for automated decision-making or profiling.
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Client data is not used to train public AI models.
4. SPECIAL CATEGORY DATA
We do not intentionally collect or process special category data as defined under GDPR.
However, where such information is voluntarily shared in the context of mentoring or reflective work, it is processed solely for the purpose of delivering the agreed service and handled with appropriate confidentiality.
5. HOW WE COLLECT YOUR PERSONAL DATA
We collect personal data:
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Directly from you (e.g. forms, emails, bookings, payments)
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Through our websites and digital platforms
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From third-party service providers involved in payments, scheduling, communication, analytics, and service delivery
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From publicly available sources where relevant and lawful
6. MARKETING COMMUNICATIONS
You will receive marketing communications from us only where:
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You have opted in, or
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You have previously engaged with our services and not opted out
You can unsubscribe at any time via links in our emails or by contacting support@hummingbirdmentoring.com
We may use Google services, including analytics or advertising-related services where applicable. Where such services are used, they operate in accordance with Google’s policies and applicable data protection laws.
7. DISCLOSURE OF YOUR PERSONAL DATA
We may share personal data with trusted third parties, including:
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Kajabi (platform provider)
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Stripe / Kajabi Payments (payment processor)
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QuickBooks (accounting platform)
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Kitchen.co (client portal provider)
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Cloudflare (hosting infrastructure)
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Google Workspace
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Scheduling platforms
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Professional advisers (accountants, legal advisers, insurers)
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Regulatory authorities where required
All third parties are required to process data securely and in accordance with data protection law.
8. INTERNATIONAL TRANSFERS
Some service providers (including Kajabi and certain technology platforms) are based outside the European Economic Area.
Where this occurs, transfers are made under recognised safeguards, including:
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The EU–US Data Privacy Framework (where applicable)
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Standard Contractual Clauses where required
9. DATA SECURITY
We use appropriate technical and organisational measures to protect your personal data. Access is limited to those who need it for legitimate business purposes. We have procedures in place to manage and report personal data breaches where legally required.
10. DATA RETENTION
We retain personal data only for as long as necessary to fulfil its purpose and meet legal obligations.
Accounting & Financial Records
For tax and accounting purposes, financial and transaction records are retained for seven (7) years.
Mentoring & Coaching Clients
Client records are retained for the duration of the working relationship and for up to six (6) months after completion of services, unless a longer retention period is required by law.
Website & Design Clients
Project materials and associated data are retained for the duration of the project and up to six (6) months following completion. After this period, client materials are deleted unless otherwise agreed.
Membership Subscribers (The Nest)
When a subscription is cancelled:
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Access to the platform is removed.
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Account details are archived.
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Financial records are retained for seven (7) years for accounting purposes.
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After the legal retention period, data may be permanently deleted.
11. YOUR LEGAL RIGHTS
Expand slightly:
Under data protection law, you have the right to:
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Access your personal data
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Request correction
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Request erasure (“right to be forgotten”)
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Restrict processing
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Object to processing
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Data portability
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Withdraw consent where consent is relied upon
Requests can be made via support@hummingbirdmentoring.com.
If you are dissatisfied, you may lodge a complaint with the Data Protection Commission (Ireland).
12. THIRD-PARTY LINKS
Our websites may contain links to third-party platforms, including but not limited to:
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YouTube
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LinkedIn
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Podcast platforms
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Insight Timer
These are provided for convenience. We are not responsible for their privacy practices.