Privacy Policy

1. Introduction

Three Centers Coaching & Consulting, a trading name of Rogowski Coaching & Consulting (“Three Centers,” “we,” “us,” or “our”) is committed to protecting the privacy and personal data of everyone who visits or interacts with our website at www.threecenters.com. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and your rights in relation to it.

We operate and serve clients in the United States, the United Kingdom, and the European Economic Area (EEA), and we comply with the applicable data protection laws in each of these jurisdictions, including:

  • The EU General Data Protection Regulation (GDPR) (Regulation 2016/679)

  • The UK GDPR and UK Data Protection Act 2018

  • Applicable US state privacy laws, including the California Consumer Privacy Act (CCPA/CPRA) where applicable

2. Who We Are (Data Controller)

Three Centers Coaching & Consulting (a trading name of Rogowski Coaching & Consulting, the legal entity responsible for your data) is the data controller for personal data collected through this website.

Contact details:

If you are located in the EU or UK and have questions about how your data is handled, you may contact us at the email address above.

3. What Personal Data We Collect

3.1 Blog & Newsletter Subscription

When you sign up for our newsletter or blog updates, we collect:

  • Your email address

  • Your first and/or last name (if provided)

This data is collected via our website, which is hosted on Squarespace, and managed through Squarespace Email Campaigns.

3.2 Contact Form

When you submit an enquiry through our contact form, we collect:

  • Your name

  • Your email address

  • Any information you choose to include in your message

3.3 Website Analytics

Our website uses Squarespace's built-in analytics tools to collect anonymised and aggregated data about how visitors use our site. This may include:

  • Pages visited and time spent on site

  • Approximate geographic region (country/city level)

  • Device type and browser

  • Referring website or URL

Squarespace analytics do not use third-party advertising cookies and do not track you across other websites. We do not use Google Analytics, Meta Pixel, or any other third-party tracking tools.

3.4 Data We Do Not Collect

We do not collect payment information, government identification numbers, health data, or any special category data as defined under GDPR.

4. Legal Basis for Processing (EU/UK Users)

For users in the EU and UK, we process your personal data on the following legal bases under the GDPR / UK GDPR:

  • When you sign up for our newsletter or blog. You may withdraw consent at any time by clicking 'Unsubscribe' in any email we send, or by contacting us directly.

  • When you submit a contact form enquiry, we process your data to respond to your message. Our legitimate interest is providing our services and managing client relationships.

  • Where data processing is necessary to take steps prior to entering into a contract with you.

5. How We Use Your Personal Data

We use the data we collect for the following purposes:

  • To send you our newsletter and blog updates (email subscribers only)

  • To respond to enquiries submitted via our contact form

  • To understand how our website is being used and improve it

  • To manage and maintain our client relationships

We will never sell, rent, or trade your personal data to third parties for marketing purposes.

6. Third-Party Service Providers

We use a limited number of trusted third-party services to operate our website. These parties act as data processors and are bound by contractual obligations to handle your data securely and only on our instructions:

  • Website hosting, contact form, newsletter subscriptions, and email campaigns. Squarespace is certified under the EU-US Data Privacy Framework and UK IDTA, providing an adequate transfer mechanism for EU/UK data.

  • Online appointment scheduling. When you book a discovery call via the Calendly link on our site, you are directed to Calendly's platform. Please review Calendly's own Privacy Policy at calendly.com/privacy.

We do not share your data with any other third parties unless required to do so by law.

7. International Data Transfers

As we operate across the US, UK, and EU, your personal data may be transferred to and processed in countries outside your own jurisdiction, including the United States. Where such transfers occur:

  • For EU users: we rely on the EU-US Data Privacy Framework (for Squarespace) or Standard Contractual Clauses (SCCs) as appropriate safeguards.

  • For UK users: we rely on the UK International Data Transfer Agreement (IDTA) or UK Addendum to SCCs as appropriate.

You may request information about the safeguards we use for international transfers by contacting us at hello@threecenters.com.

8. How Long We Keep Your Data

  • We retain your data for as long as you remain subscribed. You may unsubscribe at any time.

  • We retain correspondence for up to 3 years, after which it is securely deleted unless an ongoing client relationship requires longer retention.

  • Aggregated, anonymised analytics data is retained in accordance with Squarespace's standard retention practices.

9. Your Rights

9.1 EU and UK Residents

Under the GDPR and UK GDPR, you have the following rights:

  • Request a copy of the personal data we hold about you.

  • Ask us to correct inaccurate or incomplete data.

  • Ask us to delete your personal data ('right to be forgotten').

  • Ask us to limit how we use your data.

  • Request your data in a portable, machine-readable format.

  • Object to our processing of your data based on legitimate interests.

  • Where processing is based on consent, withdraw it at any time.

To exercise any of these rights, contact us at hello@threecenters.com. We will respond within 30 days. You also have the right to lodge a complaint with your national supervisory authority:

  • EU: Your country's data protection authority (e.g., CNIL for France, BfDI for Germany).

  • UK: The Information Commissioner's Office (ICO) at ico.org.uk.

9.2 California Residents (CCPA/CPRA)

If you are a California resident, you have the right to:

  • Know what personal information we collect and how it is used.

  • Request deletion of your personal information.

  • Opt out of the sale or sharing of personal information. (We do not sell or share personal information.)

  • Non-discrimination for exercising your privacy rights.

To exercise your California rights, contact us at hello@threecenters.com.

10. Cookies and Tracking Technologies

Our website is built on Squarespace and uses a small number of cookies necessary for the site to function correctly. Squarespace may set cookies related to:

  • Session management and security

  • Analytics (first-party, aggregated and anonymised through Squarespace Analytics)

We do not use advertising cookies, retargeting pixels, or any third-party tracking cookies. Because our analytics are first-party and anonymised, and we do not use non-essential cookies, EU/UK users are not required to consent to cookies under most interpretations of the ePrivacy Directive. However, we recommend reviewing Squarespace's Cookie Policy for full details.

Most browsers allow you to control or disable cookies through their settings. Note that disabling cookies may affect the functionality of our website.

11. Data Security

We take reasonable technical and organisational measures to protect your personal data from unauthorised access, loss, or misuse. These include:

  • Our website is served over HTTPS (SSL/TLS encryption).

  • Our website and email platforms (Squarespace) are hosted on infrastructure with industry-standard security measures.

  • We limit access to personal data to only those who need it to operate our business.

While we take these steps to protect your data, no method of transmission over the internet is 100% secure. We encourage you to be mindful of what personal information you share in contact form messages.

12. Children's Privacy

Our website and services are not directed at children under the age of 16 (or 13 in the US). We do not knowingly collect personal data from minors. If you believe a child has provided us with personal data, please contact us at hello@threecenters.com and we will promptly delete it.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we do, we will revise the 'Effective Date' at the top of this page. We encourage you to review this policy periodically. Where changes are material, we will take reasonable steps to notify you (e.g., by email to subscribers or a notice on our website).

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us:

Three Centers Coaching & Consulting

Email: hello@threecenters.com

Website: www.threecenters.com

We aim to respond to all privacy-related enquiries within 30 days.