Privacy Policy: Updated 2026

Who We Are

This Privacy Policy explains how GWA Ltd ("we", "us", "our") collects, uses and protects personal information.This policy applies to:

  • The Naturally High Performance website

  • Our workshops, programmes and services

  • The In:Genious mobile application

  • Communications with clients, participants and subscribers

GWA Ltd is the data controller responsible for the personal information described in this policy.

Contact Details

GWA Ltd Email: nikki@naturallyhighperformance.co.uk

If you have any questions about this policy or wish to exercise your data protection rights, please contact us using the details above.

Information We Collect

Depending on how you interact with us, we may collect:

Information You Provide

  • Name

  • Email address

  • Telephone number

  • Company name

  • Billing information

  • Information provided through forms, enquiries, surveys or programme participation

  • During coaching engagements, workshops and leadership programmes we may create professional notes relating to participation, discussions, actions and objectives.

Information Collected Automatically

When you visit our website or use our app, certain information may be collected automatically, including:

  • IP address

  • Browser type

  • Device type

  • Operating system

  • Website usage information

  • App usage information

  • Approximate geographic region

  • Diagnostic and performance information

How We Use Your Information

We use personal information to:

  • Deliver our services

  • Communicate with clients and participants

  • Manage contracts and business relationships

  • Respond to enquiries

  • Provide customer support

  • Improve our website, services and mobile application

  • Monitor performance and usage trends

  • Comply with legal obligations

  • Send marketing communications where permitted

Legal Bases for Processing

Under UK GDPR we process personal information using one or more of the following lawful bases.

Contract

Where processing is necessary to provide services, fulfil agreements or manage client relationships.

Examples include:

  • Delivering workshops and programmes

  • Providing coaching services

  • Managing client projects

  • Processing payments and invoices

Consent

Where you have given clear consent. Examples include:

  • Joining our mailing list

  • Receiving marketing communications

  • Accepting non-essential cookies

You may withdraw consent at any time.

Legitimate Interests

Where processing is necessary for our legitimate business interests and does not override your rights. Examples include:

  • Maintaining relationships with previous clients

  • Improving services

  • Managing business operations

  • Responding to enquiries

  • Monitoring website and app performance

Legal Obligations

Where we are required to process information to comply with applicable laws and regulations.

In:Genious Mobile Application

In:Genious is a mobile application developed and published by GWA Ltd.

The app is designed to provide educational, reflective and wellbeing-related content. It is not intended to provide medical, psychological or healthcare advice.

Information Collected by the App

The app does not require users to create an account.The app does not collect:

  • Names

  • Email addresses

  • Passwords

  • Contact lists

  • Photos

  • Camera data

  • Microphone data

  • Precise location data

  • Health data

To help us understand how the app is being used and improve the user experience, we use analytics tools (Mixpanel).

Analytics information may include device type, operating system, app version, screens viewed, content interactions, session duration, frequency of use, diagnostic information and general geographic location (country or regional level rather than precise location). Certain preferences may be stored locally on your device to improve your experience. This information is not transmitted to GWA Ltd unless explicitly stated within the application.

We do not use this information to identify individual users.

Push Notifications

Users are able to grant permission before notifications are sent. Notification preferences can be changed within device settings at any time.

Children

The app is intended for adults and is not directed towards children under 13 years of age. We do not knowingly collect personal information from children.

Service Providers

We use carefully selected third-party service providers to help us operate our business, deliver our services and improve our products. These providers may process personal information on our behalf and are contractually required to implement appropriate security and confidentiality measures.

We may share personal information with our service providers where necessary to operate our business, deliver our services, communicate with clients and maintain our website and mobile application.

We may also disclose information where required by law, regulation or legal process. We do not sell, rent or trade personal information to third parties.

Our current providers include:

Dropbox

We use Dropbox for secure cloud-based file storage, collaboration and document sharing.Information stored within Dropbox may include:

  • Client records

  • Workshop materials

  • Programme resources

  • Project documentation

  • Business administration records

  • Employee and contractor information where relevant to our business operations

Access to information stored in Dropbox is restricted to authorised members of our team and is only used for legitimate business purposes. Further information about Dropbox's privacy and security practices can be found on Dropbox's website.

Mixpanel

We use Mixpanel Analytics within the In:Genious mobile application to understand how the app is being used and to improve functionality and user experience.Mixpanel may collect information such as:

  • Device type

  • Operating system

  • App version

  • General geographic region

  • App interactions

  • Content viewed

  • Session information

  • Diagnostic and performance data

We do not use Mixpanel analytics to identify individual users.

Squarespace

We use Squarespace to host and operate our website. Squarespace may process website visitor information including IP addresses, browser information, device information and website usage data.

Omnisend

We use Omnisend to manage email communications, newsletters and marketing campaigns. Omnisend may process subscriber information including names, email addresses, subscription preferences and email engagement data such as opens and clicks.

Google Workspace

We use Google Workspace for email, calendars, document creation, file storage, forms and business administration. Personal information may be processed within Gmail, Google Drive, Google Docs, Google Sheets, Google Forms and related services.

Evernote

Evernote is used for business administration, project management, meeting notes and client records.Access to this information is restricted to authorised members of our team and is only used for legitimate business purposes.

Marketing Communications

If you subscribe to our mailing list, we may send newsletters, updates and information about services, events or programmes. We use Omnisend as our email marketing platform.

Marketing emails may contain tracking technologies that allow us to understand:

  • Email opens

  • Link clicks

  • General engagement with campaigns

You may unsubscribe at any time using the link provided in our emails or by contacting us directly.

Website Analytics and Cookies

Our website is hosted by Squarespace.

Squarespace may automatically collect information about:

  • Browser type

  • Device type

  • IP address

  • Pages viewed

  • Referring websites

We use cookies and similar technologies to:

  • Ensure website functionality

  • Improve performance

  • Understand website usage

  • Support security

Where required by law, non-essential cookies are only used after obtaining your consent.

You may manage cookie preferences through our cookie banner or browser settings.

International Transfers

Some of our service providers may process information outside the United Kingdom.

Where personal information is transferred internationally, we ensure appropriate safeguards are in place, including approved contractual protections where required under UK GDPR.

Data Retention

We retain personal information only for as long as necessary to fulfil the purposes described in this policy.

Typical retention periods include:

  • Client records: up to 7 years following the end of a client relationship

  • Marketing records: until consent is withdrawn or records become inactive

  • Financial records: as required by applicable accounting and tax legislation

  • Analytics data: according to the retention settings of the relevant platform

Information may be retained longer where required by law or where there is a legitimate business reason to do so.

Security

We take appropriate technical and organisational measures to protect personal information against: Unauthorised access, loss, misuse, disclosure, alteration and destruction.

Access to personal information is limited to those who require it for legitimate business purposes.

Your Rights

Under UK GDPR you have the right to:

  • Be informed about how your information is used

  • Access your personal information

  • Correct inaccurate information

  • Request deletion of your information

  • Restrict processing

  • Object to processing

  • Request data portability

  • Withdraw consent where consent is relied upon

  • Not be subject to certain automated decision-making processes

To exercise any of these rights, please contact us at: nikki@naturallyhighperformance.co.uk

Complaints

If you are unhappy with how we handle your personal information, please contact us first so that we can try to resolve the issue.You also have the right to lodge a complaint with the Information Commissioner's Office (ICO):https://www.ico.org.uk

Changes to This Policy

We may update this Privacy Policy from time to time.

Any updates will be published on our website and, where appropriate, within the In:Genious app.

The date at the top of this policy indicates when it was last updated.