This Privacy Policy explains how The Clique FZCO, trading as She Leads ("we", "us", "our") collects, uses, stores and protects personal information when you visit our website, purchase or participate in our programmes, communicate with us, or otherwise use our services.

We are committed to protecting your privacy and handling your personal information responsibly.

---

1. WHO WE ARE

Legal Company Name: The Clique FZCO
Trading Name: She Leads
Registered Address: Our registered office is 38th Floor, Media One Hotel- Office Tower, 334069, Dubai, U.A.E.
Company/Registration Number: 11496
Email: [email protected]
Website: www.sheleads.academy

For the purposes of applicable data protection law, we are generally the data controller of the personal information described in this Privacy Policy.

---

2. INFORMATION WE COLLECT

We may collect and process the following categories of personal information.

## 2.1 Information You Provide Directly

This may include:

* full name;
* email address;
* telephone number;
* postal or billing address;
* business or professional information;
* account login information;
* programme enrolment information;
* billing and transaction information;
* communications you send to us;
* survey responses;
* testimonials or feedback;
* coaching practice submissions;
* assessment materials;
* attendance information;
* certification information;
* information submitted through forms;
* customer service and complaint information; and
* any other information you voluntarily provide.

---

# 3. PAYMENT INFORMATION

Payments may be processed by third-party payment providers.

We may receive limited payment-related information such as:

* transaction date;
* payment amount;
* payment status;
* payment method type;
* billing details;
* payment reference numbers; and
* partial payment card information.

We do not normally receive or store full payment card details where payments are processed directly by a third-party payment processor.

Payment providers process your information in accordance with their own privacy policies and security practices.

---

# 4. PROGRAMME AND STUDENT INFORMATION

If you enrol in one of our training or certification programmes, we may collect information relating to your participation, including:

* programme access dates;
* modules accessed;
* module completion;
* assessment submissions;
* assessment outcomes;
* trainer feedback;
* live session attendance;
* coaching practice records;
* recorded coaching submissions;
* certification status;
* training hours accumulated;
* correspondence with trainers;
* student support records; and
* information necessary to administer your training and certification.

We use this information to deliver the Programme, assess progress, maintain training records, issue certifications and provide student support.

---

# 5. COACHING RECORDINGS AND PRACTICE SESSIONS

As part of certain training programmes, Students may submit recorded coaching practice sessions for assessment, feedback or certification purposes.

Such recordings may contain:

the Student's voice and/or image;
the voice and/or image of the person being coached;
personal information discussed during the coaching session; and
assessment notes and trainer feedback.

Students are responsible for obtaining appropriate consent from any person participating in a recorded coaching session before the recording is submitted to us.

Submitted recordings will only be accessed by authorised personnel, trainers, assessors or service providers where reasonably necessary for training, assessment, accreditation or administration purposes.

We will not use coaching recordings for marketing, promotional or public purposes without separate permission.

6. LIVE TRAINING SESSIONS

Live training sessions may be delivered using video conferencing or other online platforms.

Where a live session is recorded, participants will be informed where reasonably required.

Recordings may include:

participant names;
voices;
video images;
chat messages;
questions;
discussions; and
other contributions made during the session.

Where recordings are made available to Students, they must only be used for personal educational purposes and must not be copied, shared or distributed without permission.

7. INFORMATION COLLECTED AUTOMATICALLY

When you visit our website or online learning platform, certain information may be collected automatically.

This may include:

IP address;
browser type;
device type;
operating system;
approximate location;
pages visited;
referring website;
date and time of visits;
course access activity;
login activity; and
technical information about your use of our website and services.

We may collect this information through cookies, analytics tools, pixels, server logs and similar technologies.

8. COOKIES

Our website may use cookies and similar technologies.

Cookies are small files stored on your device that may help us:

operate our website;
remember user preferences;
maintain login sessions;
understand website usage;
analyse website performance;
improve our services;
measure marketing performance; and
provide relevant advertising where permitted.

Where required by law, non-essential cookies will only be used with your consent.

You may be able to manage cookies through our cookie consent tool or your browser settings.

For more information, please see our Cookie Policy, where applicable.

9. HOW WE USE PERSONAL INFORMATION

We may use personal information for the following purposes:

to create and manage customer accounts;
to process purchases and payments;
to provide access to our programmes;
to deliver training and educational services;
to manage live training sessions;
to monitor student participation;
to assess submitted work;
to provide coaching feedback;
to issue certificates;
to maintain student and accreditation records;
to respond to enquiries;
to provide customer support;
to manage complaints;
to communicate Programme updates;
to send administrative notices;
to maintain the security of our systems;
to prevent fraud and misuse;
to comply with legal obligations;
to maintain financial and tax records;
to improve our website, services and Programmes;
to conduct business analysis;
to market our services where permitted; and
to establish, exercise or defend legal claims.

10. LEGAL BASES FOR PROCESSING

Where applicable data protection law requires us to identify a legal basis for processing personal information, we may rely on one or more of the following:

Contract

Where processing is necessary to:

process your enrolment;
provide your Programme;
assess your work;
manage your account;
issue certificates;
provide student support; or
perform another contractual obligation.

Legal Obligation

Where processing is necessary to comply with legal requirements, including accounting, tax, regulatory or law-enforcement obligations.

Legitimate Interests

We may process information where reasonably necessary for our legitimate business interests, including:

operating and improving our services;
maintaining business records;
preventing fraud;
maintaining security;
managing customer relationships;
resolving disputes; and
protecting our legal rights.

We will only rely on legitimate interests where those interests are not overridden by your rights and freedoms.

Consent

Where required, we may rely on your consent, for example for:

certain marketing communications;
optional cookies;
testimonials;
photographs;
promotional materials; or
other voluntary uses of personal information.

You may withdraw consent at any time where consent is the legal basis for processing.

11. MARKETING COMMUNICATIONS

Where permitted by law, we may send you information about:

our programmes;
events;
workshops;
services;
promotions;
educational resources; and
related offers.

You may unsubscribe from marketing communications at any time by:

clicking the unsubscribe link in an email; or
contacting us at [EMAIL].

Unsubscribing from marketing communications will not prevent us from sending important administrative or Programme-related communications.

12. SHARING PERSONAL INFORMATION

We may share personal information with trusted third parties where reasonably necessary to operate our business and provide our services.

These may include:

learning management platforms;
payment processors;
email service providers;
customer relationship management systems;
video conferencing platforms;
website hosting providers;
cloud storage providers;
accounting providers;
professional advisers;
contractors;
coach trainers;
assessors;
accreditation-related organisations;
analytics providers;
IT and security providers; and
government, regulatory or law-enforcement bodies where legally required.

Third-party service providers are only authorised to process personal information for appropriate purposes and are expected to protect personal information in accordance with applicable law and contractual obligations.

13. INTERNATIONAL DATA TRANSFERS

Some of our service providers may be located outside your country of residence.

As a result, personal information may be transferred internationally.

Where applicable law requires additional safeguards for international transfers, we will take reasonable steps to ensure appropriate protections are in place.

These may include:

adequacy decisions;
approved contractual safeguards;
standard contractual clauses; or
other legally recognised transfer mechanisms.

14. HOW LONG WE KEEP PERSONAL INFORMATION

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected.

Retention periods may vary depending upon:

contractual requirements;
student certification records;
accreditation requirements;
accounting and tax requirements;
complaint or dispute handling;
legal obligations; and
the need to establish or defend legal claims.

Examples may include:

financial transaction records: [INSERT PERIOD];
certification and training records: [INSERT PERIOD];
student account records: [INSERT PERIOD];
assessment records: [INSERT PERIOD];
coaching recordings: [INSERT PERIOD];
marketing records: until consent is withdrawn or the information is no longer required.

Where information is no longer required, we will delete, anonymise or securely dispose of it where reasonably practicable.

15. DATA SECURITY

We take reasonable technical and organisational measures to protect personal information against:

unauthorised access;
accidental loss;
misuse;
alteration;
disclosure; or
destruction.

These measures may include:

access controls;
password protections;
secure hosting;
encrypted systems where appropriate;
restricted staff access;
staff confidentiality obligations;
backup procedures; and
security monitoring.

However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

16. YOUR PRIVACY RIGHTS

Depending on where you live, you may have certain rights in relation to your personal information.

These may include the right to:

request access to your personal information;
request correction of inaccurate information;
request deletion of personal information;
request restriction of processing;
object to certain processing;
withdraw consent;
request transfer of your personal information;
object to direct marketing;
lodge a complaint with a data protection authority; and
request information about how your data is being used.

These rights may be subject to legal limitations or exemptions.

To exercise a privacy right, contact:

[email protected]

We may need to verify your identity before processing certain requests.

17. ACCESS, CORRECTION AND DELETION REQUESTS

If you believe information we hold about you is inaccurate or incomplete, please contact us.

You may also request deletion of certain personal information.

However, we may need to retain some information where required for:

contractual obligations;
accreditation records;
certification verification;
tax or accounting purposes;
legal compliance;
dispute resolution; or
establishing or defending legal claims.

18. CHILDREN'S PRIVACY

Our Programmes and services are intended for individuals aged 18 or over, unless expressly stated otherwise.

We do not knowingly collect personal information from children without appropriate parental or guardian consent where such consent is legally required.

If you believe a child has provided us with personal information improperly, please contact us.

19. THIRD-PARTY WEBSITES

Our website or Programme may contain links to third-party websites, services or platforms.

We are not responsible for the privacy practices, security or content of third-party websites.

We recommend reviewing the privacy policy of any third party before providing personal information to them.

20. TESTIMONIALS AND REVIEWS

We will only use identifiable testimonials, reviews, photographs or case studies for promotional purposes where we have an appropriate legal basis to do so.

Where consent is required, we will obtain that consent separately.

You may contact us if you wish to request removal of a testimonial or promotional use of your information, subject to applicable legal and contractual limitations.

21. SOCIAL MEDIA

If you interact with us through social media platforms, information may be processed both by us and by the relevant social media platform.

Your use of those platforms is also subject to their own terms and privacy policies.

22. AUTOMATED DECISION-MAKING

We do not normally make decisions that have significant legal or similar effects solely through automated processing.

If this changes and applicable law requires disclosure, we will provide relevant information about the automated process and your associated rights.

23. DATA BREACHES

Where a personal data breach occurs, we will investigate the incident and take reasonable steps to reduce potential harm.

Where required by applicable law, we will notify the relevant data protection authority and/or affected individuals.

24. ACCREDITATION AND CERTIFICATION RECORDS

We may retain certain information relating to:

Student identity;
attendance;
training hours;
assessment;
completion;
certification; and
Programme participation

for the purposes of:

issuing certificates;
verifying training records;
maintaining accreditation records;
responding to verification requests; and
complying with professional or regulatory requirements.

Where information is required for certification verification, we may retain limited records for an extended period.

25. LEGAL CLAIMS AND PAYMENT DISPUTES

We may retain and use information where reasonably necessary to:

respond to payment disputes;
respond to chargebacks;
investigate suspected fraud;
enforce contracts;
recover unpaid amounts;
respond to legal claims; and
establish, exercise or defend our legal rights.

Relevant information may be provided to payment processors, banks, card networks, legal advisers, insurers, courts or other authorised parties where reasonably necessary for those purposes.

26. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect:

changes in our services;
changes in our systems;
changes in applicable law;
changes in regulatory requirements; or
changes in how we process personal information.

The most current version will be published on our website with the updated effective date.

Where a material change significantly affects how we process personal information, we may provide additional notice where appropriate.

27. CONTACT US

If you have questions about this Privacy Policy or how we handle personal information, please contact:

Email: [email protected]

28. COMPLAINTS

If you believe we have not handled your personal information appropriately, please contact us first so that we can investigate your concern.

You may also have the right to complain to the data protection authority in your country.

For example, where applicable:

UK: Information Commissioner's Office
EU/EEA: The relevant national supervisory authority in your country of residence or establishment.

Nothing in this Privacy Policy limits any privacy rights available to you under applicable law.