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Shanagher

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Privacy Policy – Shanagher (shanagher.com)

Last Updated: October 2026

  1. Introduction

Welcome to shanagher.com (“we,” “our,” or “us”). We provide strategic management advisory, business triage, and brand positioning services to business owners and executives.

We respect your privacy and are committed to protecting your personal data. This privacy policy informs you about how we collect, use, look after and store your personal data when you visit our website, engage our advisory services or communicate with us, as well as your privacy rights under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

  1. Important Information and Who We Are

Data Controller

For the purposes of applicable data protection law, shanagher.com is the data controller responsible for your personal data.

Contact Details

If you have any questions about this privacy policy or our data protection practices, please contact us at:

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

  1. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store, and transfer different kinds of personal data, including:

  • Identity Data: Includes first name, last name, job title, and company name.
  • Contact Data: Includes business email address, phone number, and billing/business address.
  • Technical Data: Includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types, operating system, and platform used to access this website.
  • Usage Data: Includes information about how you use our website, services, and diagnostic tools.
  • Advisory & Communication Data: Includes notes, audio/video recordings, and transcripts from diagnostic or triage calls (conducted via platforms such as Zoom/Fathom), correspondence and intake questionnaire responses provided during advisory engagements.
  • Marketing & Communications Data: Includes your preferences in receiving marketing emails from us and your communication preferences.
  1. How We Collect Your Personal Data

We use different methods to collect data from and about you, including through:

  • Direct Interactions: You may give us your Identity, Contact and Financial Data by filling in website forms, booking a triage session, subscribing to updates, or corresponding with us by email or phone.
  • Automated Technologies or Interactions: As you interact with our website, we automatically collect Technical and Usage Data about your equipment, browsing actions and patterns via cookies and server logs.
  • Third-Party Services: We receive data from third-party service providers, including calendar and scheduling tools, video conferencing and meeting transcription software (e.g., Fathom), web analytics providers and email delivery platforms.
  1. Lawful Basis and How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we process your personal data under the following lawful bases:

  1. Performance of a Contract: Where we need to perform the advisory contract we are about to enter into or have entered into with you.
  2. Legitimate Interests: Where it is necessary for our legitimate business interests (e.g., conducting strategic B2B outreach, improving our website and services, managing client relationships) and your interests and fundamental rights do not override those interests.
  3. Legal Obligation: Where we need to comply with a legal or regulatory obligation (e.g., accounting, tax and record-keeping duties).
  4. Consent: Where you have provided explicit consent (e.g., subscribing to marketing communications). You can withdraw consent at any time by contacting us or using an unsubscribe link.

Summary of Processing Activities

Purpose / Activity

Type of Data

Lawful Basis for Processing

To onboard you as a client and conduct advisory/triage sessions

Identity, Contact, Advisory

Performance of a contract

To process bookings, invoices, and payments

Identity, Contact, Financial

Performance of a contract; Legal obligation

To record and transcribe strategic meetings (e.g., via Fathom)

Identity, Advisory Data

Legitimate interests (to deliver accurate strategic summaries and advice)

To manage our relationship with you (updates, policy changes)

Identity, Contact

Performance of a contract; Legal obligation

To deliver relevant website content, insights, and marketing

Identity, Contact, Marketing

Legitimate interests (B2B business development) or Consent

To administer and protect our business and website

Technical, Usage

Legitimate interests (running our business, IT security)

  1. Disclosures of Your Personal Data

We do not sell, rent or trade your personal data. We may share your personal data with trusted third parties solely for the operations of our business:

  • Service Providers: Professional cloud software providers acting as data processors, including website hosting, scheduling platforms, CRM tools, video conferencing and automated meeting recording tools (e.g., Fathom), email automation tools and accounting software.
  • Professional Advisers: Accountants, legal counsel and insurers where necessary for professional advice or legal compliance.
  • Legal Authorities: Regulatory bodies, law enforcement or statutory authorities where required by UK law.

All third-party processors are contractually required to respect the security of your personal data and to treat it in accordance with the law.

  1. International Data Transfers

Some of our third-party service providers (such as cloud hosting, scheduling and software platforms) are based outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • Transferred to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government.
  • Subject to specific contractual clauses approved for use in the UK (such as the UK International Data Transfer Agreement or Addendum) which give personal data the same protection it has in the UK.
  1. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorized way, altered, or disclosed. Access to your personal data is restricted to those who have a genuine business need to know, subject to strict duties of confidentiality.

  1. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including satisfying any legal, accounting or reporting requirements.

  • Client Advisory Files & Accounting Records: Retained for up to 6 years following the end of the client relationship to comply with UK tax regulations and legal claims limits.
  • Meeting Recordings & Transcripts: Retained for the duration of the engagement or up to 12 months after completion, after which they are securely deleted or anonymized.
  • Marketing Contacts: Retained until you request to unsubscribe or opt out of communications.
  1. Your Legal Rights

Under the UK GDPR, you have the following rights regarding your personal data:

  • Request access to your personal data (commonly known as a “data subject access request”).
  • Request correction of inaccurate or incomplete personal data.
  • Request erasure of your personal data where there is no good reason for us continuing to process it.
  • Object to processing of your personal data where we rely on a legitimate interest.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data to you or a third party (data portability).
  • Withdraw consent at any time where we rely on consent to process your personal data.

If you wish to exercise any of these rights, please contact us via email at nick@shanagher.com. We aim to respond to all legitimate requests within one month.

  1. Third-Party Links & Cookies

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

Cookies

Our website uses essential cookies for site functionality and may use analytical cookies to help us improve user experience. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.

  1. Changes to This Privacy Policy

We review and update this privacy policy regularly to reflect changes in our legal duties or service offerings. Any updates will be posted directly on this page.