Privacy Policy

Russell and Company SARL-S

Last updated: March 2026

Who we are

Russell and Company SARL-S (a company registered in Luxembourg) runs this site and is responsible for how your personal data is handled (we're the data controller, in GDPR terms).

I'm Richard — this is a one-person coaching practice. When you share your data with "us", it's actually just me who receives it, me who decides how it's used, and me who you can contact if you have any questions or concerns.

What data we collect

Data you give us

  • Your name and email when you sign up to a mailing list or download a resource

  • Information you share when booking a call or completing a contact form

  • Information you share during coaching or facilitation work

Data collected automatically

  • Website analytics data (pages visited, referral source, session behaviour) via Google Analytics and similar tools

  • Advertising and retargeting data via Meta Pixel and similar tools

  • Cookie and device data — see our Cookie Notice

Why we collect it

Here's why we collect it, and what gives us the right to do so (lawful bases under GDPR):

  • Consent: when you sign up to a mailing list, accept tracking cookies, or agree to session recording

  • Contract: to deliver coaching or facilitation services you have engaged us for

  • Legitimate interests: to understand how the site is used and improve our content and services

What we do with your data

  • Send you emails you have opted into

  • Respond to enquiries and manage coaching engagements

  • Retarget you with relevant advertising (if you have consented to tracking cookies)

  • Improve our site and content

We do not sell your data to third parties.

AI tools and voice transcription

We use AI-powered tools to help run our business — including content creation, note-taking, summarisation, and analysis. Some of these tools process data on servers outside the EU/EEA, and some providers may use interaction data to improve their own models. We choose tools carefully and use GDPR-compliant agreements where we can. With AI tools especially, we don't always have full control over what happens to data once it's processed — we're happy to tell you what we're using and why.

We use voice transcription tools and AI analysis to take notes during and after sessions. These tools may process the content of conversations. We will ask for your explicit consent before transcribing any session.

Third party tools and processors

We use the following services, each with its own privacy policy and data handling practices:

Tool

Purpose

GoHighLevel

Website, CRM, and mailing list. Data may be processed in the US.

Google Analytics

Website analytics. Processed by Google under their privacy policy.

Meta Pixel

Advertising and retargeting. Processed by Meta under their privacy policy.

Stripe

Payment processing. We do not handle card data directly.

Substack

Newsletter distribution. Data held by Substack under their own terms.

Cal.com

Call scheduling.

Voice transcription tools such as Omi, Granola, and tools integrated into Google Meet, Zoom, etc.

Session note-taking. Data may be stored and processed by the provider.

AI tools (Claude, ChatGPT, OpenClaw, and others)

Content and analysis support. Providers may process data per their own policies.

We make reasonable efforts to use services with GDPR-compliant data processing agreements where available. Some AI tools operate under terms that limit our control over downstream data handling.

International transfers

Several tools listed above transfer data outside the EU/EEA, including to the United States. Where possible, we rely on Standard Contractual Clauses or equivalent mechanisms. Where such mechanisms are not available, we have assessed the transfer as justified by the legitimate business purpose, while acknowledging the limitation.

How long we keep your data

  • Mailing list subscribers: until you unsubscribe or request deletion

  • Coaching clients: session notes retained for up to 3 years after the engagement ends, then deleted

  • CRM and contact records: deleted after 3 years of inactivity

  • Analytics data: per Google Analytics retention settings (default 14 months)

Your rights

Under GDPR you have the right to:

  • Access the data we hold about you

  • Correct inaccurate data

  • Request deletion of your data

  • Withdraw consent at any time (this does not affect the lawfulness of prior processing)

  • Object to or restrict certain processing

  • Lodge a complaint with a supervisory authority

In Luxembourg, you can raise a complaint with the Commission Nationale pour la Protection des Données (CNPD): (https://cnpd.lu)

To exercise any of these rights: [email protected]

If data has gone through a third-party tool, we may not be able to retrieve or delete it from their side. We'll always be straight with you about that.

Changes to this policy

We may update this policy from time to time. The current version will always be on this page with the date it was last updated.

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