Privacy Policy

Ask David: AI Coaching Assistant
Operated by DeepQuery Ltd on behalf of Clutterbuck Coaching and Mentoring International (“CCMI”).

1. Who We Are

This platform is operated by DeepQuery Ltd (“DeepQuery”), a company registered in England and Wales (Company No. 16919713), registered office at 128 City Road, London, EC1V 2NX. DeepQuery is registered with the Information Commissioner's Office (ICO) as a data processor. ICO Registration Number: ZC108829.

The platform is provided on behalf of Coaching and Mentoring International Ltd (“CCMI”), registered office at Woodlands, Tollgate, Maidenhead, Berkshire, SL6 4LJ (company number 08158710). CCMI is registered with the Information Commissioner's Office (ICO). ICO Registration Number: ZA467620.

For UK GDPR purposes:

• CCMI is the Data Controller
• DeepQuery is the Data Processor
• Collectively referred herein as “We” or “Us”

For any privacy-related enquiries, contact: help@deepquery.dev

2. What Data We Collect

When you use Ask David, we collect the following personal data:

Identity and contact data

• Your email address (used to create and manage your access)
• Your role / job description
• The country you live in
• Your full name

Conversation data

• Text messages you send to the AI assistant
• Voice recordings of your spoken input during voice sessions
• Transcripts of your conversations with the assistant

Usage data

• Session duration and timestamps
• Voice minutes consumed
• Feature usage patterns
• Platform login activity

Feedback data

• Ratings or comments you provide on individual AI responses

Technical data

• Device type and browser information
• IP address

We do not collect payment card data directly. Payment processing is handled by Stripe, a PCI-DSS compliant third-party payment provider.

3. How We Use Your Data

We process your personal data solely for the following purposes:

• Creating and managing your access to the platform
• Operating your subscription and processing payments
• Operating the AI assistant and generating responses to your queries
• Providing us with usage data and quality assurance information via a secure dashboard
• Recording and analysing feedback you provide on individual AI responses to improve the platform
• Improving the accuracy and quality of the AI assistant's responses
• Sending you essential communications about your account or the service

We do not use your conversation data for marketing, commercial profiling, or any purpose other than those listed above.

4. Voice and Conversation Recording

By using this platform, you consent to the recording, processing and storage of your voice and written messages sent via this platform. We may review conversation data solely to assess whether the AI assistant's responses are consistent with David Clutterbuck's coaching methodologies and professional standards. We are contractually prohibited from using conversation data for marketing or any purpose beyond quality oversight.

You must not include in your conversations and messages any identifiable details of other parties (such as clients, co-coaches or supervisors names) without their express written permission to do so.

You are also advised not to include in your conversations and messages anything about yourself or other parties that would be regarded as sensitive / special category data (such as information on health, political or sexual orientation, racial or ethnic type or other personal disclosures). Where this occurs, we rely on your explicit consent provided at registration under UK GDPR Article 9(2)(a).

If you do not wish to have your conversations recorded and reviewed, please do not use this service.

5. Legal Basis for Processing

We process your personal data on the following legal bases under UK GDPR:

• Contract: processing necessary to provide the subscription service you have signed up for
• Consent: you provide explicit consent via the platform registration process before first use. You may withdraw your consent at any time by contacting us, though this will mean you can no longer use the platform
• Legitimate interests: operating and improving the platform in a manner consistent with your reasonable expectations

Conversation data may incidentally include special category data (such as health information or personal disclosures). Where this occurs, we rely on your explicit consent provided at registration under UK GDPR Article 9(2)(a).

6. Data Retention

You may request deletion of your account and data at any time. Requests must be submitted from your registered account email, and we may take reasonable steps to verify your identity before actioning a request. We will delete your personal data within 30 days.

We may retain fully anonymised and aggregated data from which you cannot be identified, for the purpose of platform improvement. This anonymised data is not subject to deletion requests.

7. Third-Party Service Providers

To operate this platform, DeepQuery engages third-party service providers in the following categories:

• AI infrastructure, voice processing and language model services
• Database, authentication and encrypted storage services
• Platform hosting, content delivery and compute infrastructure
• Payment processing (Stripe)

All third-party providers are subject to appropriate data protection safeguards including Standard Contractual Clauses (SCCs) or equivalent UK-approved transfer mechanisms under UK GDPR.

A full register of sub-processors is available upon request.

Data locations: Your data may be processed and stored on servers located in the United Kingdom, European Union or United States, depending on which service provider is handling a given operation. Where technically feasible, servers in closest geographic proximity to you may be used. All international transfers are conducted under appropriate legal safeguards.

8. Your Rights

Under UK GDPR, you have the right to:

• Access: request a copy of the personal data we hold about you
• Rectification: request correction of inaccurate data
• Erasure: request deletion of your data
• Restriction: request that we limit processing of your data
• Object: object to processing based on legitimate interests
• Withdraw consent: withdraw your consent to processing at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal

To exercise any of these rights, please contact CCMI in the first instance as Data Controller:

CCMI: DPO@clutterbuck-cmi.com

For technical matters relating to your data on the platform, you may also contact DeepQuery:

DeepQuery: help@deepquery.dev

We will respond within the statutory 30-day period.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk if you believe your data has been handled unlawfully.

9. Security

We implement appropriate technical and organisational security measures to protect your personal data, including:

• Encryption of data in transit and at rest
• Access controls limiting data access to authorised personnel only
• Regular security testing
• Encrypted backups

In the event of a personal data breach, we will notify the ICO within 48 hours in accordance with our obligations under UK GDPR.

10. Cookies

This platform uses cookies to provide and improve the service. We use essential cookies to maintain your session and authentication, and analytics cookies to understand how the platform is used and to identify errors. We do not use advertising or tracking cookies such as those used by Meta, Google Ads or similar platforms. If you block cookies, some features of the platform may not function correctly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated to you via email or on-platform notification. Continued use of the platform following notification constitutes acceptance of the updated policy.

12. Contact

For any questions about this Privacy Policy or how your data is handled, please contact CCMI as Data Controller in the first instance:

CCMI (Data Controller)
Email: DPO@clutterbuck-cmi.com
Woodlands, Tollgate, Maidenhead, Berkshire, SL6 4LJ

For technical platform queries:

DeepQuery Ltd (Data Processor)
Email: help@deepquery.dev
128 City Road, London, EC1V 2NX