Privacy Policy

Isabella Brusati & Associates
Website: https://isabellabrusati.com
Last updated: 31 October 2026

1. Who We Are

This website is operated by Isabella Brusati, trading as Isabella Brusati & Associates, an independent executive coaching and change management advisory practice based in Italy.

For the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), Isabella Brusati is the Data Controller.

Contact: info@isabellabrusati.com

2. Personal Data We Collect

We may collect and process the following personal information:

Information you provide directly: Your name, email address, organisation and any information you voluntarily include when contacting us or subscribing to our newsletter.

Newsletter information: Your email address, subscription preferences, consent and confirmation records, and information relating to newsletter delivery and engagement, where provided by our email marketing platform.

Technical information: Information necessary to operate and secure the website, which may include IP addresses, browser information, access times and server logs.

We do not intentionally request sensitive personal data through this website. Please avoid including sensitive information in contact enquiries.

3. How We Use Your Information

We process personal data for the following purposes:

Responding to enquiries: To respond to requests for information about our services and communicate with prospective clients.

Newsletter communications: To send articles, professional insights and updates about transformation leadership, organisational change and executive coaching, where you have subscribed.

Website operation and security: To maintain the website, investigate technical problems, prevent misuse and protect our services.

Legal obligations: To comply with applicable legal and regulatory requirements.

4. Legal Bases for Processing

We rely on the following legal bases under Article 6 of the GDPR:

  • Consent (Article 6(1)(a)): For sending newsletter communications to subscribers.
  • Pre-contractual measures (Article 6(1)(b)): Where processing is necessary to respond to requests concerning potential professional engagements.
  • Legitimate interests (Article 6(1)(f)): For appropriate website security, maintenance and administration, subject to balancing these interests against individuals’ rights.
  • Legal obligations (Article 6(1)(c)): Where processing is required by applicable law.

5. Newsletter and Briefing Subscriptions

Our newsletter, The Leadership Behind Transformation, provides perspectives on transformation leadership, organisational change and related professional topics.

Newsletter subscriptions are collected through forms provided by Bloom and managed using MailerLite.

We use a double opt-in process, meaning subscribers are asked to confirm their email address before their subscription becomes active.

You may withdraw your consent and unsubscribe at any time using the unsubscribe link included in our emails or by contacting info@isabellabrusati.com.

We do not automatically subscribe individuals who contact us through the website.

Our decision ownership and transformation decisions briefing forms offer a resource delivery email followed by five daily emails. These forms use MailerLite and an unchecked consent box. New email subscribers are asked to confirm their address; an existing active subscriber may not receive a new confirmation request. The resource is also available as a direct download without joining the email series. Choosing a briefing series does not add you to a separate ongoing newsletter.

6. Contact Enquiries, Optional Surveys and Bookings

If you contact us through our website, we use the information you provide to respond to your enquiry and, where relevant, discuss a potential professional engagement.

We do not use contact enquiries to add individuals to our newsletter without their separate consent.

The optional briefing surveys collect your email address and selected answers about your role, current decision challenge and interest in a conversation. We use these answers to offer the relevant next step and review enquiries. Survey responses are sent to our website administrator by email. Completing a survey does not subscribe you to additional marketing, and the worked example is available whether or not you request a session. Please do not include names of colleagues or confidential organisational information.

Introductory conversations are booked through TidyCal. Booking information is used to arrange the requested meeting. Contact details and agreed follow-up actions may be recorded in our Excel contact tracker. Coaching notes are not collected through the resource signup or survey.

7. Service Providers

We use third-party services to operate our website and manage communications.

These include:

Krystal Hosting: Website hosting and related infrastructure.

WordPress, Divi and Bloom: Website publishing, design and newsletter form functionality.

MailerLite: Newsletter and briefing subscription management, email delivery and related subscriber administration, including delivery and engagement information.

Contact Form 7: Optional survey submission and email notification through the WordPress website.

TidyCal: Appointment booking for requested introductory conversations.

These services process the information needed to provide their respective functions. Contact us using the details above for further information about the providers involved in handling your request.

8. International Data Transfers

Some service providers may process or access personal data outside the European Economic Area.

Where international transfers occur, we seek to ensure that they are subject to an applicable legal transfer mechanism and appropriate safeguards, such as an adequacy decision or Standard Contractual Clauses, as required by the GDPR.

Further information about relevant safeguards can be requested using the contact details above.

9. Data Retention

Prospects and enquiries: We retain enquiry correspondence, optional survey responses and prospect contact-tracker records for up to 24 months after our last meaningful contact, unless a professional engagement begins or a specific legal obligation or dispute requires longer retention. Meaningful contact means a reply, meeting, new enquiry or agreed follow-up; sending an unanswered marketing email does not restart this period. Records are then deleted or anonymised.

Email subscriptions: We retain the information needed to deliver a requested briefing series or newsletter while that subscription remains active. A completed briefing series does not create an ongoing newsletter subscription. Where there is no continuing subscription, engagement or meaningful contact, the 24-month prospect retention period applies. Unsubscribing stops marketing emails; we may retain a minimal suppression record for as long as needed to honour that choice and prevent accidental re-subscription, and limited consent evidence where necessary to demonstrate compliance.

Client and statutory records: Contracts, invoices and records relating to a professional engagement are handled separately from prospect marketing records. They are retained for the applicable contractual, accounting, tax and legal-claims periods. Coaching-record arrangements are explained in the relevant engagement documentation.

Technical records and backups: Security and operational logs are retained only for the period needed to operate and protect the service under our hosting arrangements. Deleted records may remain in restricted backups until those backups are overwritten in the normal cycle; they are not used for marketing. If restoration is necessary, applicable deletion and suppression choices must be reapplied.

10. Cookies and Similar Technologies

Our website is configured for essential functionality only. We do not use Google Analytics, advertising pixels, remarketing, visitor heatmaps or session-replay tools. Bloom form-view and conversion tracking and its optional cookies are disabled.

Website operation and security: WordPress may use necessary cookies for login, authenticated sessions and administration. These support access and security for authorised users; visitors do not need to log in to read our pages or download the briefings. Hosting and security services may process technical connection information to deliver and protect the website.

Forms: Our briefing signup forms load MailerLite resources to validate and submit the form. Form services may use necessary session or submission information to complete a request and prevent duplicate submissions. We do not use MailerLite pop-ups, shopping-cart tracking or embedded MailerLite surveys on this website. Our optional briefing questionnaires use Contact Form 7. The newsletter form uses Bloom with its optional cookie and statistics functions disabled.

External websites: Booking links open TidyCal, and other links may take you to services such as LinkedIn. Those services apply their own privacy and cookie choices when you visit them. A link does not itself embed their tracking tools on our pages. Email delivery and engagement information is separate from website cookies and is described in the subscription and service-provider sections above.

You can block or remove cookies through your browser settings. Blocking necessary cookies may affect login or form functionality. We do not ask for consent to optional tracking while it is disabled. If optional tracking is introduced in future, it will remain off until you give any required consent, and this notice will be updated. See MailerLite’s information about form cookies for its form technology.

11. Your Rights

Under the GDPR, you may have the right to:

  • Access personal data held about you.
  • Request correction of inaccurate personal data.
  • Request deletion of your personal data.
  • Request restriction of processing.
  • Object to processing in certain circumstances.
  • Request data portability where applicable.
  • Withdraw consent at any time, without affecting processing previously carried out lawfully.

To exercise these rights, contact info@isabellabrusati.com.

You also have the right to lodge a complaint with a competent supervisory authority. In Italy, this is the Garante per la protezione dei dati personali (https://www.garanteprivacy.it).

12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our website, services, data processing activities or applicable legal requirements.

The date at the beginning of this policy indicates when it was last updated.

13. Contact

For questions about this Privacy Policy or how your personal data is processed, please contact:

Isabella Brusati
Trading as Isabella Brusati & Associates
Italy
Email: info@isabellabrusati.com