Privacy Policy

 Brightpath Partners Ltd (the "Company", "we", "us") respects the privacy of everyone who visits this website (http://chris-perkins.com), uses our services, including our AI digital clone "Mini ChrisP", and/or interacts with our coaching programmes. This Privacy Policy explains how we collect, use, store, and protect your personal information.

Unfortunately, no data transmission over the Internet is guaranteed to be 100% secure. As such, the Company cannot ensure or warrant the security of any information you transmit via the internet. By transmitting any such information to the Company, you accept that you do so at your own risk, and to the maximum extent permitted by law we disclaim liability for unauthorised access arising from circumstances beyond our reasonable control. 

This privacy statement is subject to change by the Company at its discretion; provided that we will provide advance notice of any material changes (Changes to this Privacy Policy). It is your responsibility to review this statement periodically. By continuing to access or otherwise use the Company's website or services, you agree to the terms of this Privacy Policy. If you do not agree to these terms, please do not access or use this site or our services. 

1.  INFORMATION WE COLLECT

1.1  Website Visitors

When you visit our website, we may collect basic information that does not identify individual users, including: the specific pages visited, the page that referred you to our site, and information about your browser and operating system. This information does not include any personally identifiable information.

1.2  Personal Information You Provide

Personally identifiable information, such as your name, email address, home address, photographs, and other information, will not be collected unless you willingly and voluntarily submit such information to us. We only collect information from persons 18 years of age or older. When you:

•  Purchase our products or services

•  Register for our programmes or downloads

•  Subscribe to our email list or newsletter

•  Submit a contact form or inquiry

•  Access our AI digital clone (Mini ChrisP)

We will only store the information you provide in the required fields, and we do not request or intentionally collect sensitive personal information (such as government identifiers, health data, or financial account numbers) through our Website or Mini ChrisP. 

1.3  Mini ChrisP Digital Clone - Data Collection

Mini ChrisP is currently offered as a free service during our beta phase. When you access Mini ChrisP, our AI digital clone built on the Coachvox platform (https://coachvox.ai), we collect:

•  Your name and email address (required for access)

•  Password credentials (optional - only if you choose to create an account to save chat history)

•  The content of your conversations with Mini ChrisP

•  Metadata related to your interactions (timestamps, session duration)

•  Technical information (IP address, browser type, device information)

•  Basic usage data necessary for service delivery

We do not review or analyse individual user conversations for analytics, training purposes, or service improvement beyond what is necessary for immediate service delivery, security, abuse prevention, and quality assurance. 

1.4  Data Controller Relationship with Coachvox

IMPORTANT: For Mini ChrisP services, data control is shared between Brightpath Partners Ltd and Coachvox Ltd. (the platform provider), and we have entered into appropriate written agreements governing such processing and allocation of responsibilities under applicable law:

• Account Data (your name, email, and password if you create one): Brightpath Partners Ltd is the sole data controller; Coachvox acts as a processor on our instructions.
• Conversation Data (your chats with Mini ChrisP): Both Brightpath Partners Ltd and Coachvox are joint controllers. We both determine why and how this data is processed for service delivery, quality assurance, security/abuse prevention, and limited technical improvement that does not use your content to train unrelated third-party models.
• Safety Logs (IP addresses, timestamps, abuse flags): Coachvox controls this data independently for platform security and legal compliance; however, Coachvox processes such data subject to contractual restrictions with us and applicable law.
• Your conversations with Mini ChrisP may be accessed by Brightpath Partners Ltd and, when necessary for technical service delivery or platform security, by the Coachvox team. Both parties treat your content as confidential.
• You can exercise your data rights (access, correction, deletion, portability, objection) with either Brightpath Partners Ltd or Coachvox, and we will cooperate to ensure your request is addressed; we may request reasonable information to verify your identity and may deny manifestly unfounded or excessive requests as permitted by law. See Section 9 below for contact information. 

2.  HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

• To provide and deliver our coaching services, programs, and products
• To operate Mini ChrisP and deliver responses to your queries
• To respond to your inquiries and provide customer support
• To send you information about our products and services (only with your express permission, and you may withdraw consent at any time)
• To enhance your online experience and improve our website
• To prevent fraud and diagnose technical problems
• To comply with legal obligations
• To maintain basic usage statistics necessary for service delivery (not for detailed analytics or training), including aggregated and de-identified metrics that do not identify you.

We will never sell personally identifiable information to third parties, and we do not sell or share personal information for cross-context behavioural advertising as those terms are defined under U.S. state privacy laws. We do not control and are not liable for the actions of any third parties. 

IMPORTANT: Email addresses collected through Mini ChrisP access are maintained separately from our general marketing email list. By agreeing to our terms to access Mini ChrisP, you are also opted in to receive our newsletter, or other marketing communications. 

You always have the choice to opt out of receiving future electronic mailings by clicking the "unsubscribe" link at the bottom of any email from us or by contacting us directly.

3.  DATA SHARING AND DISCLOSURE

3.1  Service Providers

We share your information with trusted third-party service providers who assist us in operating our business, including:

• Coachvox Ltd.: AI platform provider for Mini ChrisP (see Section 1.4 above regarding joint controller arrangement)
• Stripe: Payment processing (Stripe handles all payment data; we do not have access to or store credit card information)
• Email service providers: For sending newsletters and communications (separate from Mini ChrisP access)
• Analytics providers: For website analytics only
• Cloud hosting providers: For data storage and infrastructure

These service providers are bound by confidentiality, security, and data protection obligations and are only authorised to use your information as necessary to provide services to us or as required by law. 

3.2  Legal Requirements

We may disclose your personally identifiable information when we have a good-faith belief that such disclosure is necessary to identify, contact, or bring legal action against someone who may be causing injury to, or interference with, our rights or property, other users of the site, or anyone else that could be harmed by such activities, or to enforce our Terms and policies. We may also disclose information when required by law or to protect the safety of our users or the public.

3.3  International Data Transfers

Your personal data may be transferred to and stored in countries outside the United States and the European Economic Area (EEA), including the United Kingdom, where Coachvox is based. We ensure appropriate safeguards are in place to protect your data in accordance with applicable data protection laws, including by relying on adequacy decisions where available and the European Commission’s Standard Contractual Clauses (and UK IDTA/Addendum, as applicable), supplemented by transfer impact assessments and additional safeguards where required. 

4.  DATA SECURITY AND RETENTION

4.1  Security Measures

We implement appropriate technical and organisational security measures designed to protect your personal information from unauthorized access, alteration, disclosure, or destruction and to ensure a level of security appropriate to the risk. For Mini ChrisP specifically:

• All data is encrypted in transit and at rest
• Access to user data is restricted to authorised personnel only
• Regular security assessments and updates are performed
• Coachvox maintains industry-standard security practices for platform infrastructure

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security and are not responsible for breaches caused by events beyond our reasonable control.

4.2  Data Retention 

We retain your information for as long as necessary to provide our services and fulfill the purposes outlined in this Privacy Policy. Specifically:

• Account information: Until you request deletion or until the earlier of (a) you asking us to delete the information, (b) our decision to cease using our existing data providers, (c) the Company decides that the value in retaining the data is outweighed by the costs of retaining it, or (d) we are required to delete or anonymise the data under applicable law or pursuant to retention schedules.
• Mini ChrisP conversation data: We retain conversation data for 12 months after your last interaction, or until you request deletion, whichever comes first. You may request deletion at any time by contacting us.
• Marketing communications data: Until you unsubscribe or request deletion
• Transaction records: As required by law (typically 7 years for tax purposes)
• Security logs: Coachvox maintains minimal security logs as needed for platform protection and legal compliance, typically for 30-90 days 

5.  COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to enhance your experience on our website, and where required by law we will obtain your consent before setting non-essential cookies. Cookies are small files of information that a website transfers to your computer's hard drive (if your computer allows it) to recognise your browser and capture certain information.

Cookies make using our site easier by saving your preferences; certain cookies and similar technologies may involve the processing of personal data, which we handle in accordance with this Privacy Policy and applicable law. Most browsers are initially set up to accept cookies; however, if you prefer not to receive cookies, you may alter your browser configuration to refuse cookies. If you choose to have your browser refuse cookies, some areas of our site may not function as effectively.

We honour Do Not Track (DNT) browser signals and do not track, plant cookies, or use advertising when a DNT mechanism is in place.

Coachvox may also use cookies and similar technologies for the Mini ChrisP platform. You can review Coachvox's cookie practices at https://coachvox.ai/privacy/. 

6.  THIRD-PARTY LINKS

Our website may include links to other websites not under our control, and we are not responsible for the privacy or security practices of such websites. These third-party sites may request information from you. The collection and use of your personally identifiable information will be governed by the privacy policy in effect on that third-party site. We do not control the privacy statements, information, and links that may appear on other sites. You are responsible for reviewing the privacy statements of third-party sites before providing any information to them. 

7.  CHILDREN'S PRIVACY

Our website and services, including Mini ChrisP, are intended for persons 18 years of age or older, and we do not knowingly collect personal information from individuals under 18; if you believe a minor has provided information to us, please contact us so we can take appropriate action. We do not knowingly collect personal information from individuals under 18 years of age. If you are under 18, you are not permitted to use this website or our services and must not submit any information under any circumstances. If we become aware that we have collected personal information from someone under 18, we will delete that information immediately. 

8.  YOUR PRIVACY RIGHTS

8.1  California Residents (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), subject to applicable exemptions and our ability to verify your request:

• Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, purposes, and categories of third parties, for the 12‑month period preceding your request (and longer to the extent required by law)
• Right to Delete: Request deletion of your personal information, subject to legal, security, and operational exceptions (e.g., to complete transactions, detect security incidents, comply with law, or enable internal uses reasonably aligned with consumer expectations)
• Right to Correct: Request correction of inaccurate personal information, taking into account the nature of the personal information and our purposes for processing it
• Right to Opt-Out: Opt out of the "sale" or "sharing" of personal information; however, we do not sell personal information or share it for cross‑context behavioral advertising as those terms are defined by the CPRA.
• Right to Limit Use of Sensitive Personal Information: You may direct us to limit our use and disclosure of sensitive personal information to uses permitted by the CPRA; we in any event use sensitive information only as necessary to provide the services you request and as otherwise permitted by law 
• Right to Non-Discrimination: You will not receive discriminatory treatment for exercising your privacy rights; however, we may offer price or service differences, including financial incentives, that are reasonably related to the value of your data and provided pursuant to a written notice that explains the material terms as permitted by law

To exercise these rights, contact us at chris.perkins@brightpathpartners.co.uk or use the contact information in Section 9 below; we will take reasonable steps to verify your identity (and authority, if acting as an authorised agent) before fulfilling a request, and we may deny or limit requests as permitted by law. You may also choose to unsubscribe from email lists by clicking the "unsubscribe" link at the bottom of all emails from the Company. 

8.2  Other U.S. State Residents (Colorado, Connecticut, Utah, Virginia)

If you are a resident of Colorado, Connecticut, Utah, or Virginia, you have similar rights to California residents, subject to applicable statutory exceptions and our ability to verify your request, including:

• Right to access the personal information we hold about you
• Right to request deletion of your personal information, subject to legal, security, and operational exceptions (e.g., to complete transactions, detect security incidents, comply with law, or for internal uses reasonably aligned with your expectations)
• Right to request correction of inaccurate information, taking into account the nature of the data and our purposes for processing it
• Right to opt out of the sale or targeted advertising (Colorado, Connecticut, Utah, Virginia) and the sharing of personal information for cross‑context behavioral advertising (Colorado, Connecticut, Virginia); however, we do not sell personal information or engage in targeted advertising or cross‑context behavioral advertising as defined by applicable law.
• Right to data portability in a portable and readily usable format
• Right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects (Colorado, Connecticut, Virginia); we do not engage in such profiling.

To exercise these rights, contact us using the information in Section 9 below; we will take reasonable steps to verify your identity (and authority, if acting as an authorised agent) and respond within 45 days, which we may extend once by an additional 45 days where reasonably necessary and permitted by law. If we deny your request, you may appeal by replying to our decision email, and if your appeal is denied, you may contact your state attorney general. 

8.3  European Union and UK Residents (GDPR/UK GDPR)

If you are within the European Union or the United Kingdom, you are entitled to certain information and have certain rights under the EU GDPR and the UK GDPR, subject to applicable exemptions and our ability to verify your identity and authority (where an agent acts on your behalf): 

• Right of Access: Request access to your personal data that we store
• Right to Rectification: Request correction of inaccurate or incomplete personal data
• Right to Erasure: Request deletion of your personal data where one of the grounds in Article 17 applies, subject to statutory exceptions (including compliance with legal obligations and the establishment, exercise, or defense of legal claims)
• Right to Restriction: Seek restrictions on the processing of your data in the circumstances set out in Article 18 (e.g., contesting accuracy or pending an objection)
• Right to Object: Object at any time to processing for direct marketing (including profiling) and, where processing is based on legitimate interests, object on grounds relating to your particular situation
• Right to Data Portability: Receive and transmit to another controller your personal data in a structured, commonly used, and machine‑readable format where processing is based on consent or contract and carried out by automated means
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time 
• Right to Lodge a Complaint: Lodge a complaint with your local supervisory authority (or the UK ICO, as applicable) if you consider that our processing infringes data protection law
• Right to Information: We will provide the information required by Articles 13 and 14 and will not condition the provision of services on consent where consent is not the appropriate legal basis

For Mini ChrisP services specifically, you can exercise your EU/UK data protection rights with either Brightpath Partners Ltd or Coachvox Ltd. by contacting hello@coachvox.com; . See Section 1.4 for details on the joint controller arrangement. 

9.  CONTACT INFORMATION AND EXERCISING YOUR RIGHTS

If you have any questions or concerns about this Privacy Policy, wish to exercise your privacy rights, or want to update your preferences, please contact us:

Brightpath Partners Ltd

Email: chris.perkins@brightpathpartners.co.uk 

Website:http://chris-perkins.com  

For matters specifically related to Mini ChrisP and the Coachvox platform: Coachvox Ltd.

Email: hello@coachvox.com Website: https://coachvox.ai/privacy/  

10.  CAN-SPAM ACT COMPLIANCE

In compliance with the CAN-SPAM Act, all emails sent from our organisation clearly state who the email is from and provide clear information on how to contact the sender. All email messages contain concise information on how to unsubscribe from our mailing list so that you receive no further email communications from us.

Users who no longer wish to receive our newsletter or promotional materials may opt out by clicking the unsubscribe link in any email. After unsubscribing, we will discontinue sending the particular messages as soon as technically feasible. 

11.  CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you by:

• Posting the updated policy on our website with a new "Effective Date"," 
• Sending an email notification to your registered email address (for material changes)
• Displaying a prominent notice on our website or within Mini ChrisP

We encourage you to review this Privacy Policy periodically. Your continued use of our website or services after changes become effective constitutes your acceptance of the revised Privacy Policy.

Brightpath Partners Ltd 

Last Updated: 17th February, 2026