Pincer Lead Engine (“Pincer”, “we”, “us”, “our”) provides training and implementation services to coaches.
Legal entity: Energetic English Ltd.
Registered address: Suite A, 82 James Carter Road, Mildenhall, Suffolk, UK, IP28 7DE
Contact for privacy matters: [email protected]
This policy explains how we collect, use, share, and protect your information when you visit our websites, landing pages, and funnels, sign up for content, or book a call.
We are established in the UK and primarily comply with UK GDPR and PECR. For visitors from the US, we also address U.S. state privacy laws (including California CCPA/CPRA; see §13). If these laws conflict, the protections most favourable to you apply.
Contact details: name, email, phone (optional).
Business information: role, tenure, revenue band, goals/bottlenecks (from application forms).
Calendar details: your selected time zone and chosen time slot.
Communications: emails, messages, and call notes/recordings (if we record, we’ll say so at the start).
Usage/Device data: IP address, device IDs, browser type/version, pages viewed, UTM parameters, time on page, referrer/exit pages.
Event data: opt-ins, application starts/submissions, bookings, video engagement (e.g., “Primer viewed”).
We use cookies, pixels (e.g., Meta Pixel/CAPI), and local storage. See §10 Cookies for details and your choices.
Purpose Examples Legal basis Provide services / fulfil requests Send VSL link, process applications, schedule calls, deliver materials, customer support. Contract (Art. 6(1)(b)) Operate & secure the site Load balancing, fraud prevention, security logs. Legitimate interests; Legal obligations Analytics & product improvement Measure opt-in/App→Book/Show% to improve pages and comms. Legitimate interests Marketing communications Send reminders, useful resources, program updates. Consent (email/SMS); or legitimate interests where permitted (opt-out anytime) Advertising & retargeting Meta ads measurement/retargeting. Consent (for non-essential cookies/ads in UK/EU); Legitimate interests in some non-EU regions Legal & compliance Record-keeping, exercising/defending legal claims. Legal obligations; Legitimate interests
Legitimate interests test: We only rely on this where our interests (e.g., running a safe, useful site) do not override your rights. You can object at any time (see §11).
We do not sell your personal information for money. We may share with:
Service providers (processors): website hosting/CDN, CRM & funnel software (e.g., GHL), email/SMS tools, calendar/meeting tools (e.g., Google/Zoom), ad platforms (Meta) for measurement/retargeting, analytics, consent management.
Ad/analytics partners: via pixels/CAPI when you consent (UK/EU).
Professional advisors & authorities: where required by law or to protect rights/security.
We sign data processing agreements (DPAs) with our processors.
We may transfer data outside the UK/EEA (e.g., to the US) using approved safeguards such as UK IDTA/EU SCCs, and supplementary measures where appropriate. Copies of relevant safeguards are available on request (with redactions for security/commercial sensitivity).
We keep data no longer than necessary for the purposes above:
Leads/contacts: 24 months after last interaction (or earlier if you unsubscribe and request deletion).
Application responses: 24 months (for audit/consistency).
Calendar & reminders data: 12–24 months.
Ad/analytics event data: typically 13 months (provider default) unless law or disputes require longer.
We then delete or anonymise.
We use reasonable technical and organisational measures (encryption in transit, access controls, least-privilege, regular reviews). No method is 100% secure. If we suspect a personal data breach that risks your rights, we will notify you and relevant authorities where required.
Our services are not directed to children. We do not knowingly collect data from anyone under 16. If you believe a child has provided data, contact us and we’ll delete it.
Strictly necessary (essential): site operation, security, form submissions, cookie preferences.
Performance/analytics: understand visits, funnel metrics.
Advertising/retargeting: measure ads, show ads to interested visitors (e.g., Meta).
UK/EU: Under PECR/UK GDPR, non-essential cookies require prior consent. Our banner lets you Accept all / Reject non-essential / Manage preferences. You can change your choice anytime via the “Cookie Settings” link in the footer.
US: You can opt-out of “sale/sharing” for cross-context behavioural advertising via “Do Not Sell or Share My Personal Information” (footer). We honour Global Privacy Control (GPC) signals where feasible.
Browsers: You can also block/delete cookies via browser settings (may affect site features).
Tool Type Purpose Duration Consent cookie Essential Remembers your cookie choices 6–12 months Session cookie Essential Load balancing, form flow Session Analytics cookie Performance Page & funnel metrics 13 months Meta Pixel / CAPI Advertising Measurement & retargeting (with consent in UK/EU) Up to 2 years (per provider)
We’ll update our CMP list with actual cookie names/IDs as deployed.
You can access, correct, erase, or restrict your data; object to processing (including profiling/marketing); withdraw consent; and port your data. We’ll respond within 1 month (extendable by 2 months for complex requests). To exercise rights: [email protected].
You can also complain to the ICO: ico.org.uk.
We do not make decisions with legal/similar significant effects based solely on automated processing. We may use basic profiling (e.g., analytics segments, ad audiences) to improve relevance. You can object at any time.
For California residents (and similarly for CO/CT/VA/UT where applicable):
Categories collected: identifiers (name, email, IP), commercial info (booking/application activity), internet activity (pages/events), inferences (basic audience segments).
Purposes: see §4; Sources: you, your devices, ad/analytics partners; Recipients: service providers and ad partners.
Sale/Share: We do not sell personal info for money. We may “share” identifiers/internet activity for cross-context behavioural advertising via pixels. You can opt-out via “Do Not Sell or Share My Personal Information” and by enabling GPC.
Rights: know/access, correct, delete, opt-out of sale/share, limit use of sensitive info (we don’t collect sensitive categories), and non-discrimination.
How to exercise: email [email protected] or use the links in the footer. We will verify your request (we may need additional info). You can use an authorised agent (we may require proof of authorisation).
Email/SMS: You can unsubscribe at any time via the link in our messages or by contacting us.
Ads: Use Cookie Settings (UK/EU), Do Not Sell/Share (US), and platform settings (Meta, etc.) to limit personalised ads.
We’ll post any updates here with a new “Last updated” date. If changes materially affect you, we’ll notify you via email or banner.
Questions or requests: [email protected]
Postal: Energetic English Ltd., Suite A, 82 James Carter Road, Mildenhall, Suffolk, UK, IP28 7DE