Privacy Policy

PRIVACY POLICY

Last Updated: March 03, 2025

Introduction

Your privacy is important to Thoroughgood Development ("we," "our," or "us"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you engage with our coaching, training, and consultancy services. Please read this Privacy Policy carefully. By accessing or using our services, you acknowledge that you have read, understood, and agreed to be bound by all the terms outlined in this Privacy Policy.

1. Information We Collect

1.1 Personal Information

We may collect personal information from you when you use our services, including but not limited to:

Identity information (name, gender)
Contact information (email address, phone number, postal address)
Professional information (job title, company, industry)
Financial information (payment details for our services)
Service data (information provided during consultations, coaching sessions, or training)
Technical data (IP address, browser type, device information)

1.2 Sensitive Personal Information

We may collect certain categories of sensitive personal information, such as:

Information about your professional development needs
Information shared during coaching or consultancy sessions
Other sensitive information you voluntarily provide to us

1.3 Collection Methods

We collect information through:

Direct interactions (when you contact us, register for our services, or complete forms)
Automated technologies (cookies, server logs, and other similar technologies)
Third parties (business partners, service providers)

2. Legal Basis for Processing

We process your personal information on the following legal bases:

Contractual necessity: To perform our contract with you for providing coaching, training, or consultancy services
Legitimate interests: To operate and improve our business and services
Consent: Where you have given us explicit consent to process your data
Legal obligation: To comply with legal requirements

3. How We Use Your Information

Your information may be used to:

Provide and manage our coaching, training, and consultancy services
Process payments and maintain financial records
Communicate with you regarding your sessions, inquiries, and service updates
Improve our services and customer experience
Send you promotional materials, if you have opted in to receive them
Comply with legal obligations
Protect our rights, privacy, safety, or property

4. Cookies and Tracking Technologies

We use cookies and similar tracking technologies on our website to collect and use personal information about you and to improve your experience. You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of our website may become inaccessible or not function properly.

Types of cookies we use:

Essential cookies: Required for basic website functionality
Analytical/performance cookies: To count visits and analyse how visitors use our website
Functionality cookies: To recognise you when you return to our website
Targeting cookies: To record your visit to our website and the pages you have visited

5. Data Retention

We retain your personal information for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

The period needed to provide you with our services
Legal requirements to retain data for certain periods
Relevant statutes of limitations
Resolution of disputes
Enforcement of our agreements

We will securely delete or anonymise your personal information when it is no longer needed for the purposes for which it was collected.

6. Data Protection

We implement appropriate technical and organisational measures to protect your personal information from unauthorised access, use, or disclosure. These measures include:

Encryption of sensitive data
Secure network architectures
Access controls to limit data access to authorised personnel
Regular security assessments

However, no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

7. International Data Transfers

As we operate globally, your personal information may be transferred to, stored, and processed in countries outside the UK and European Economic Area (EEA). When we transfer your personal information to countries that may not provide the same level of data protection as your country, we ensure appropriate safeguards are in place, such as:

Standard Contractual Clauses approved by the European Commission
Adequacy decisions where applicable
Other legally valid transfer mechanisms

By providing us with your information, you acknowledge these transfers, storing, and processing activities.

8. Sharing Your Information

We do not sell, trade, or otherwise transfer your personal information to outside parties without your consent, except as described below:

Service providers: Third parties who perform services on our behalf (e.g., payment processing, IT services)
Business transfers: In connection with any merger, sale of company assets, financing, or acquisition
Legal requirements: When required by law, court order, or governmental regulation
Protection of rights: To protect our rights, property, or safety, or that of our users or others

Any third parties with whom we share your information are contractually required to implement appropriate security measures and only process your personal information for specified purposes.

9. Your Rights

Depending on your location, you may have the following rights regarding your personal information:

Right to access: Request a copy of the personal information we hold about you
Right to rectification: Request correction of any inaccurate information
Right to erasure: Request deletion of your personal information in certain circumstances
Right to restrict processing: Request restriction of processing in certain circumstances
Right to data portability: Request transfer of your information to you or a third party
Right to object: Object to processing based on legitimate interests or direct marketing
Rights related to automated decision-making: Not be subject to decisions based solely on automated processing

To exercise these rights, please contact us using the details provided in the "Contact Us" section. We may need to request specific information to confirm your identity. We will respond to all legitimate requests within one month, unless the request is particularly complex.

10. Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal information, please contact us, and we will take steps to delete the information.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date. Material changes will be notified to you by email or a notice on our website. We encourage you to review this policy periodically.

12. Contact Us

If you have any questions about this Privacy Policy, our data practices, or wish to exercise your rights, please contact us.

13. Complaints

If you are concerned about how we handle your data, you have the right to complain to the Information Commissioner's Office (ICO) in the UK or your local data protection authority. However, we would appreciate the opportunity to address your concerns before you approach a data protection authority, so please contact us in the first instance.