Privacy Notice

JB Reinvent™ is operated by B Hamill, a sole trader based in England.

For data-protection purposes, B Hamill trading as JB Reinvent™ is the data controller responsible for personal information processed in connection with this website and the services provided by JB Reinvent.

Contact: hello@jb-reinvent.com

This Privacy Notice explains what personal information we collect, why we use it, how we protect it, who we may share it with, how long we keep it and the rights available to you.

Depending on how you interact with JB Reinvent, we may collect:

Enquiry and contact information

This may include:

• your name;
• email address;
• telephone number;
• WhatsApp contact details;
• information you include in an enquiry; and
• correspondence between you and JB Reinvent.

Please do not provide medical, mental-health or other sensitive personal information through the website enquiry form or WhatsApp unless it is genuinely necessary.

Client information

If you become a client, we may also process information such as:

• contact and identity information;
• information needed to administer our client relationship;
• programme objectives and goals;
• questionnaire and exercise responses;
• reflections and information you choose to share during the programme;
• session notes and records;
• appointment and communication records;
• contractual information; and
• payment, invoice and transaction information.

We aim to collect only information reasonably necessary for the purpose for which it is being used.

Website and technical information

Depending on the technologies used by the website, we may receive limited technical information such as:

• IP address;
• browser and device information;
• security and diagnostic information; and
• information required for the website to operate.

We do not currently intend to use advertising trackers or behavioural advertising technologies on the website.

If this changes, this Privacy Notice and any required cookie or consent arrangements will be updated.

We normally obtain personal information directly from you, including when you:

• contact us through the website;
• send us an email;
• contact us through WhatsApp;
• arrange an introductory conversation;
• become a client;
• complete programme exercises or questionnaires;
• attend coaching sessions; or
• otherwise communicate with JB Reinvent.

We may also receive limited information from service providers involved in appointments, communications, payments or delivery of the service.

We may use personal information to:

• respond to enquiries;
• arrange introductory conversations;
• determine whether JB Reinvent's services may be appropriate for you;
• establish and administer a client relationship;
• provide coaching and personal-development services;
• prepare for and document sessions;
• personalise programme materials and exercises;
• manage appointments;
• communicate with clients;
• process payments and maintain financial records;
• respond to complaints;
• manage safeguarding, referral or professional-boundary issues where necessary;
• protect our legal rights;
• comply with legal, regulatory, tax and accounting obligations;
• maintain the security and operation of our systems; and
• improve the administration and delivery of our services.

We will not use your personal information for a materially different purpose without considering whether further information or another lawful basis is required.

Under UK data-protection law, we must have a lawful basis for processing personal information.

Depending on the circumstances, we may rely on:

Contract — where processing is necessary to take steps at your request before entering into a contract or to perform our agreement with you.

Legitimate interests — where processing is reasonably necessary to operate, administer, secure and improve JB Reinvent, respond to enquiries, maintain appropriate business records or protect our legal interests, provided those interests are not overridden by your rights and interests.

Legal obligation — where information must be processed to comply with applicable law, including tax, accounting or other legal requirements.

Consent — where we specifically ask you to consent to a particular use of your information and consent is the appropriate lawful basis.

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.

Coaching and personal-development conversations can sometimes involve personal matters.

You may therefore voluntarily disclose information that falls within the legally protected categories known as "special category data", including information concerning:

• physical or mental health;
• racial or ethnic origin;
• religious or philosophical beliefs;
• sexual orientation; or
• sex life.

JB Reinvent does not require you to provide sensitive information that is unnecessary for the services being provided.

Where we intentionally process special-category personal information, we will identify both an appropriate lawful basis for processing and a separate condition permitting processing of special-category information under applicable data-protection law.

Where appropriate, this may involve asking for your explicit consent.

Where explicit consent is relied upon, it will be requested separately and will identify the relevant sensitive information and purpose of the processing.

We apply additional care to the collection, use, disclosure and security of sensitive information.

JB Reinvent may use artificial intelligence ("AI") and AI-enabled software to support its business operations and the delivery of its services.

AI may be used for purposes such as:

• administrative support;
• preparation and organisation of programme materials;
• drafting and editing educational content;
• organisation or summarisation of information;
• identifying themes within information supplied by a client;
• developing reflective questions or exercises; and
• preparing draft session materials or summaries.

AI is used as a supporting tool and does not replace human judgement.

Where an AI-generated output relates materially to an individual client, appropriate human review will be applied before it is relied upon in providing services or making a material decision concerning that client.

AI-generated information may be incomplete or inaccurate and will not automatically be treated as fact or as a professional assessment of a client.

Within the services currently provided by JB Reinvent, we will not knowingly use AI to:

• diagnose a mental-health condition;
• diagnose a physical-health condition;
• prescribe medical or psychological treatment;
• provide psychotherapy;
• make a clinical assessment;
• independently determine whether a client presents a suicide or self-harm risk;
• provide legal, regulated financial or medical advice; or
• make solely automated decisions producing legal or similarly significant effects concerning a client unless the proposed processing has first been lawfully assessed and all applicable safeguards implemented.

AI will not independently determine whether someone is suitable for JB Reinvent's services or whether a safeguarding or professional referral is required.

Responsibility for material client decisions remains with JB Reinvent.

Where reasonably necessary, approved AI-enabled systems may process information such as programme responses, goals, client reflections, questionnaire responses, session-related information or other material voluntarily supplied during the client relationship.

We aim to minimise the amount of identifiable information provided to AI systems.

Where reasonably practicable and appropriate, information may be minimised, pseudonymised or anonymised before being processed through an AI-enabled service.

We will not provide personal information to an AI provider merely because doing so is convenient.

Before using an AI service to process client personal information, we will take reasonable steps appropriate to the nature and risk of the processing to consider its privacy, confidentiality, security, retention, international-transfer and contractual arrangements.

The JB Reinvent website is built and hosted using Lovable and associated cloud infrastructure.

When you visit the website, limited technical information may be processed in connection with hosting, securing and operating the website. This may include information such as your IP address, browser and device information, timestamps, diagnostic information and other technical request or security data.

Lovable and its infrastructure providers may process personal information where necessary to provide website hosting and related services. Lovable may also process certain service, usage or log information for its own security, analytics and service-operation purposes in accordance with its own privacy terms.

Where you submit an enquiry through the website, JB Reinvent aims to minimise the processing and retention of that information by website infrastructure providers. Enquiries are intended to be delivered directly to JB Reinvent's business email and are not intended to be retained in a website customer database.

We periodically review the data-processing and international-transfer arrangements of material technology providers used by JB Reinvent.

We may use trusted third-party providers to help operate JB Reinvent.

Depending on the systems in use, these may include providers of:

• business email;
• appointment scheduling;
• video conferencing;
• payment processing;
• bookkeeping or accounting;
• secure document or cloud storage;
• communications;
• professional business systems; and
• approved AI-enabled services.

These providers may process personal information on our behalf where necessary to provide their services.

We may also disclose information where reasonably necessary to:

• professional advisers;
• insurers;
• accountants;
• legal advisers;
• regulators;
• law-enforcement bodies; or
• other persons where disclosure is required or permitted by law.

We do not sell client personal information.

Some technology providers may process or store information outside the United Kingdom.

Where personal information is transferred internationally and data-protection law requires safeguards, we will take reasonable steps to ensure an appropriate lawful transfer mechanism or safeguard applies.

Where services are provided to individuals whose information is protected by the EU GDPR, we will also consider applicable EU data-transfer requirements.

Client information is treated confidentially.

However, confidentiality may be limited where disclosure is required by law or where there is a sufficiently serious safeguarding or safety concern and disclosure is lawful and necessary.

Where disclosure is considered necessary, we will aim to disclose only information reasonably necessary for the relevant purpose.

JB Reinvent is not an emergency, medical, psychiatric or crisis-support service.

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected and to meet applicable legal, accounting, insurance and dispute-management requirements.

As a general approach:

• unsuccessful or unprogressed enquiries will normally be deleted when they are no longer reasonably required;
• routine correspondence will be retained only for as long as it remains relevant;
• client records may be retained for an appropriate period following the end of the client relationship to meet professional, insurance and legal requirements;
• financial and transaction records will be retained for the period required by applicable tax and accounting law; and
• information processed on the basis of consent will be reviewed when consent is withdrawn or the information is no longer required.

Specific retention periods may be maintained in JB Reinvent's internal data-retention schedule.

Information will be securely deleted, anonymised or otherwise disposed of when it is no longer required.

We take reasonable technical and organisational measures appropriate to the nature of the information we process.

These may include:

• access controls;
• strong authentication;
• multi-factor authentication where available;
• reputable cloud and technology providers;
• restricting access to information;
• maintaining separate business systems where appropriate;
• data minimisation;
• secure deletion; and
• procedures for responding to suspected personal-data breaches.

No internet-based system can be guaranteed to be completely secure, but we take reasonable steps to protect the information entrusted to us.

Submitting an enquiry does not automatically subscribe you to marketing communications.

Where consent is required for electronic marketing, we will obtain it separately.

You can opt out of marketing communications at any time using the unsubscribe mechanism provided or by contacting us.

Depending on the circumstances and applicable law, you may have rights including the right to:

• ask for access to personal information we hold about you;
• ask us to correct inaccurate or incomplete information;
• ask us to delete personal information in certain circumstances;
• ask us to restrict processing in certain circumstances;
• object to certain processing;
• receive certain information in a portable format;
• withdraw consent where processing is based on consent; and
• raise concerns about how your personal information is being handled.

These rights are not absolute and their availability depends on the circumstances and lawful basis for processing.

To exercise a right, contact: hello@jb-reinvent.com

We may need to verify your identity before responding to a request.

If you have concerns about how JB Reinvent handles your personal information, please contact us first at: hello@jb-reinvent.com

You also have the right to complain to the UK supervisory authority:

Information Commissioner's Office (ICO)
Website: ico.org.uk

If you are located in the European Economic Area and EU GDPR applies to the relevant processing, you may also have the right to complain to the competent data-protection supervisory authority in your country.

JB Reinvent's current services are intended for adults aged 18 and over.

We do not knowingly provide the current coaching programme to children.

We may update this Privacy Notice as our services, technology, legal requirements or business operations change.

The current version will be published on the JB Reinvent website and the "Last updated" date will be amended when material changes are made.

Questions about this Privacy Notice or the use of your personal information should be sent to:

B Hamill trading as JB Reinvent™
Email: hello@jb-reinvent.com