Privacy Policy
Last updated 11th September 2026
Introduction
SME Growth Ltd trading as Heart to Heart Sales (“Heart to Heart Sales”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal information.
This Privacy Policy explains what information we collect, why we collect it, how we use and protect it, who we may share it with, and the rights you have over your information.
It applies to our websites, services, courses, assessments and other online services, including those associated with:
- hearttoheartsales.com
- hearttoheartsales.co.uk
- beckycolwell.com
- beckycolwell.co.uk
- yourfirstsalesperson.com
- yourfirstsalesperson.co.uk
It also applies when you work with us directly, attend an event or training session, communicate with us, or use one of our client, course or assessment platforms.
This Privacy Policy applies to our clients, prospective clients, website visitors and other people who interact with our business, wherever they are located. Where local data protection or privacy laws provide additional rights that apply to you, we will respect those rights as required by law.
1. Who we are
SME Growth Ltd trading as Heart to Heart Sales is the data controller responsible for your personal information. This means we decide how and why your personal information is used.
Heart to Heart Sales provides sales training, consultancy, mentoring, online courses, assessments and related business services.
Some of our services are delivered using third-party technology platforms. Where those providers process personal information on our behalf, they generally act as our data processors and are required to handle that information appropriately.
2. The information we may collect
The information we collect depends on how you interact with us and which services you use.
It may include:
Contact and identity information, such as your name, business name, job title, email address, telephone number and other contact details.
Business information, including information about your business, clients, sales activity, processes, challenges, goals, team and other information you choose to share with us while working together.
Assessment and course information, including answers you provide to questions, forms or assessments; your progress through programmes or courses; and results, reports or recommendations generated from your responses.
Appointment and communication information, including meeting bookings, emails, messages, WhatsApp conversations and notes relating to our work together.
Meeting information, which may include recordings, transcripts, summaries and notes where a meeting is recorded or transcribed.
Transaction and account information, including information about products or services purchased, invoices, payment status and accounting records. We do not normally receive or store your full payment-card details ourselves.
Website and technical information, such as IP address, browser or device information, pages visited and information collected through cookies or analytics technologies where these are in use.
Marketing preferences, including whether you have chosen to receive or stop receiving particular types of marketing communication.
We may also receive information contained within documents or other materials that you choose to provide to us as part of consultancy, mentoring, training or other professional work.
We ask you not to provide personal information about other people unless it is reasonably necessary for the work we are undertaking together and you are entitled to share it with us.
3. How we collect your information
We may collect personal information:
- directly from you when you contact us, make an enquiry, book an appointment or purchase a service;
- when you complete a form, assessment, questionnaire, course or programme;
- during meetings, consultancy, mentoring, training or other work together;
- when you communicate with us by email, telephone, WhatsApp or social media;
- through our websites, CRM, booking systems and client platforms;
- when you attend one of our events or workshops;
- when you publicly interact with Heart to Heart Sales, for example by leaving a review;
- through referrals, networking or other legitimate business introductions; and
- through website cookies and analytics technologies where applicable.
4. Why we use your information
We only use personal information where we have a lawful reason to do so.
Depending on the circumstances, we may use your information:
To provide services you have requested or purchased.
This includes administering your account, providing courses or assessments, communicating with you, booking appointments, producing reports and recommendations, delivering consultancy or mentoring and providing customer support.
Our lawful basis will normally be that the processing is necessary to perform our contract with you or to take steps at your request before entering into a contract.
To operate and improve our business and services.
This may include maintaining appropriate business records, improving our programmes and systems, managing client relationships and understanding how our services are used.
Where appropriate, we rely on our legitimate interests in running and improving our business, provided those interests do not override your rights and interests.
To meet our legal and regulatory obligations.
For example, we are required to retain certain accounting and transaction records.
To send marketing communications where permitted.
Depending on the circumstances, this may be based on your consent or our legitimate interests and the applicable rules governing electronic marketing.
Where consent is the appropriate lawful basis, you can withdraw it at any time.
5. Service communications and marketing
There is an important difference between communications needed to provide a service and marketing communications.
If you purchase or register for a service, we may send you information necessary to deliver that service. This can include appointment confirmations and reminders, course-access information, assessment results, changes affecting the service and other administrative communications.
These are service communications and are not dependent on you agreeing to receive our newsletter or other marketing.
We may separately send you information about Heart to Heart Sales services, courses, events or other things we think may be relevant to you where we are permitted to do so.
You can opt out of marketing communications at any time using the unsubscribe or opt-out option provided or by contacting us.
Opting out of marketing will not prevent us from sending communications genuinely necessary to provide a service you have requested or purchased.
We maintain appropriate records of marketing preferences so that we can respect your choices.
This distinction reflects current ICO guidance: genuinely administrative/customer-service messages aren't direct marketing, provided promotional material isn't added to them. Electronic marketing to individuals and sole traders is also subject to PECR requirements concerning consent/soft opt-in and easy opt-outs.
6. Courses, assessments and Your First Salesperson
Some of our services involve online courses, assessments or personalised reports.
For example, Your First Salesperson includes an assessment in which you provide information about your business, sales activity, processes and readiness to employ a salesperson.
Information you submit may be processed using artificial intelligence to analyse your responses and produce personalised observations, results and recommendations.
These outputs are designed to support our professional service and your own business decision-making.
Where a service includes a personalised review by Becky Colwell, AI-generated information may form part of the material reviewed in providing that service.
Your assessment responses are not used by Heart to Heart Sales to train public AI models.
Your First Salesperson is currently delivered using ClientsOnline, which provides the assessment workspace and related technology. ClientsOnline processes information on our behalf in order to provide that service.
7. Our use of artificial intelligence
We may use trusted AI-enabled tools in parts of our work.
Depending on the service, these tools may assist with activities such as:
- analysing information you have provided;
- producing initial summaries or working materials;
- processing assessment responses;
- summarising or transcribing meetings;
- developing or organising recommendations; and
- supporting administrative or professional work.
We remain responsible for the professional services we provide.
We take reasonable steps to avoid providing AI systems with personal information that is unnecessary for the task and to use services and settings appropriate to the information being processed.
We do not use AI to make solely automated decisions about you that produce legal or similarly significant effects.
Where a particular product or service makes substantial use of AI, we may provide additional information explaining that processing.
8. Meetings, recordings and transcripts
Some meetings, workshops or training sessions may be recorded or transcribed using services such as Zoom or Fathom.
Where appropriate, we will make participants aware that recording or transcription is taking place.
Recordings and transcripts may be used to:
- provide agreed recordings or resources;
- help us accurately capture what was discussed;
- prepare notes, summaries or follow-up work;
- support delivery of the service; and
- improve our materials or services where appropriate.
We will not intentionally publish a private client meeting recording without appropriate permission.
9. WhatsApp and other communications
Where appropriate, we may use WhatsApp for client support and communications.
If you choose to communicate with us through WhatsApp or another third-party communication service, information is also processed according to that provider's own privacy arrangements.
You should avoid sending highly sensitive or unnecessary personal information through messaging services.
10. Testimonials and reviews
We may use testimonials and feedback to tell others about our services.
Where feedback has been given privately, we will normally obtain your permission before publishing it in a way that identifies you, for example by using your name, business name, photograph or other identifying information.
We may use feedback anonymously where you cannot reasonably be identified.
Where you have chosen to publish a review or recommendation publicly - for example on Google or LinkedIn - we may refer to or reproduce that public review in connection with Heart to Heart Sales. Personal information that has been made public remains subject to data-protection law, and we will use it reasonably and in context.
If you have concerns about our use of a testimonial or review, please contact us.
11. Payments and financial information
Payments may be processed through third-party payment providers such as Stripe.
Payment providers process payment information according to their own privacy and security arrangements. We do not normally receive or retain your complete card details.
We use accounting and financial systems, including FreeAgent, to maintain appropriate accounting, invoicing and tax records.
Some financial information must be retained to comply with our legal obligations.
12. Systems and service providers
We use trusted third-party providers to help operate our business and deliver our services.
These currently include services used for:
- CRM, course delivery, forms, bookings and communications, including GoHighLevel through FEA Create;
- YFPS assessment and AI-enabled processing, including ClientsOnline;
- email, business productivity and cloud file storage, including Microsoft and OneDrive;
- online meetings, recording and transcription, including Zoom and Fathom;
- client communications, including WhatsApp;
- occasional forms, including Google Forms;
- payment processing, including Stripe;
- accounting, including FreeAgent;
- website hosting and related technology; and
- analytics services where these are enabled.
These providers may process personal information on our behalf or, in some circumstances, operate as separate data controllers for aspects of their services.
We only share information that is reasonably necessary for the relevant purpose.
We do not sell your personal information.
13. International processing
Some technology providers we use operate internationally, which means personal information may sometimes be processed or stored outside the United Kingdom.
Where UK data-protection law requires safeguards for an international transfer, we take reasonable steps to ensure that appropriate safeguards or other lawful transfer mechanisms are in place.
These may include UK adequacy regulations, approved contractual safeguards or another mechanism permitted under UK data-protection law.
14. Cookies and website analytics
Our websites may use cookies and similar technologies that are necessary for the websites to function.
We may also use analytics technologies to understand how people find and use our websites and to help us improve them.
Where non-essential cookies or technologies require consent, we will provide an appropriate choice before using them.
The technologies used on our websites may change over time. Where appropriate, more detailed information will be provided through our website cookie notice or consent mechanism.
15. How long we keep information
We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including meeting legal, accounting and reporting requirements.
Different types of information may therefore be kept for different periods.
For example:
- financial and accounting records are retained for the period required by applicable law;
- active client information is normally retained while we are working together and for an appropriate period afterwards to maintain business records and deal with queries;
- marketing information is retained while it remains relevant or until you opt out, although we may retain limited suppression information so that we can remember and respect your opt-out;
- recordings and transcripts are retained only for as long as they remain reasonably necessary for the purpose for which they were created; and
- course and assessment information may be retained while your account or service remains active and afterwards where reasonably necessary to provide the service, maintain appropriate records or deal with queries.
We periodically review information we hold and delete or anonymise information that we no longer need.
16. Keeping your information secure
We take reasonable technical and organisational measures to protect personal information against accidental loss, unauthorised access, alteration, disclosure or misuse.
These measures include using reputable technology providers, appropriate account and access controls, and limiting access to personal information to people who need it for legitimate business purposes.
No internet-based service can guarantee absolute security, but we take our responsibility for protecting your information seriously.
17. Your data-protection rights
Depending on the circumstances, UK data-protection law gives you rights including the right to:
- ask for access to personal information we hold about you;
- ask us to correct inaccurate or incomplete information;
- ask us to delete personal information in certain circumstances;
- ask us to restrict how we process your information;
- object to certain processing, including an absolute right to object to the use of your personal information for direct marketing;
- withdraw consent where we rely on consent;
- receive certain information in a portable format where the right to data portability applies; and
- raise concerns about how your personal information has been handled.
These rights do not apply in exactly the same way in every situation. For example, we may sometimes be legally required to retain information even after you have asked us to delete it.
To exercise one of your rights, please contact us using the details below.
18. Data-protection complaints
If you are concerned about how SME Growth Ltd and/or Heart to Heart Sales has collected, used, stored or otherwise handled your personal information, we want you to tell us so that we can investigate it.
Please email [email protected], and make it clear that your message concerns a data-protection or privacy complaint.
We will:
1. acknowledge your data-protection complaint within 30 days;
2. consider and investigate the issues you have raised;
3. contact you if we reasonably need further information; and
4. let you know the outcome of our investigation without unjustifiable or excessive delay.
If we cannot complete our investigation within 30 days, we will keep you informed about its progress where appropriate.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent data-protection regulator.
Information Commissioner's Office – make a data protection complaint
The new complaints obligations apply to organisations handling personal data; the ICO confirms that complaints must be acknowledged within 30 days and appropriately investigated, with the outcome communicated.
19. Contacting us
For questions about this Privacy Policy, your personal information or your data-protection rights, please contact:
SME Growth Ltd trading as Heart to Heart Sales
For the attention of: Becky Colwell
Email: [email protected]
20. Changes to this Privacy Policy
We may update this Privacy Policy from time to time, for example when our services, technology providers or legal obligations change.
The latest version will be published on our website with its most recent update date.
© Copyright 2026 Heart to Heart Sales
SME Growth Ltd t/a Heart to Heart Sales Company no. 16294347