Made on
Tilda
PRIVACY POLICY
Information We Collect
1 - Legal Basis for Processing
1.1. We process your personal data in accordance with the UK General Data Protection Regulation and only where we have a lawful basis to do so.
1.2. The lawful bases on which we rely for processing your personal data are:
(a) Consent: Where you have given us clear and specific consent to process your personal data for particular purposes, including marketing communications and promotional materials about our services.
(b) Contract: Where processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract, including delivering the Thryve3 programme services and arranging onboarding calls.
(c) Legitimate Interests: Where we have a legitimate business interest in processing your personal data, provided this does not override your fundamental rights and freedoms.
1.3. Our legitimate interests include:
(a) Operating and improving our business and the Thryve3 programme.
(b) Communicating with you about our services and responding to your enquiries
(c) Ensuring the security of our systems and preventing fraud.
(d) Analysing programme effectiveness and participant outcomes.
1.4. Where we rely on legitimate interests, you have the right to object to such processing at any time.
1.5. Where we rely on your consent, you may withdraw your consent at any time by contacting us using the details provided in this Privacy Policy.
2 - How We Use Your Information
2.1. We use your personal data for the following primary purposes in connection with the Thryve3 programme:
(a) to contact you to arrange and conduct onboarding calls and initial consultations;
(b) to assess your suitability for the programme and understand your personal and professional development goals;
(c) to provide executive coaching and life coaching services tailored to your requirements;
(d) to deliver the Transcendental Meditation programme and related well-being services
(e) to monitor your progress throughout the three-month programme duration.
2.2. We also use your personal data for administrative and business purposes:
(a) to maintain accurate records of programme participants and their progress;
(b) to process payments and manage billing arrangements;
(c) to send you programme-related communications, updates, and materials;
(d) to comply with our legal and regulatory obligations.
2.3. We may use your personal data for legitimate business interests:
(a) to improve our services and programme content based on participant feedback and outcomes;
(b) to conduct internal research and analysis for business development purposes;
(c) to protect our business interests and prevent fraud or misuse of our services.
2.4. Where we rely on your consent as the legal basis for processing, you may withdraw such consent at any time by contacting us using the details provided in this Privacy Policy.
3 - Data Sharing and Recipients
3.1. We may share your personal data with the following categories of recipients in connection with the Thryve3 programme:
(a) Our executive coaches and life coaches who will be delivering coaching services as part of your programme participation.
(b) Certified instructors of Transcendental Meditation who will be providing meditation instruction and guidance.
(c) Our employees, contractors and consultants who require access to your information to administer the programme and provide customer support.
3.2. We may also share your personal data with third-party service providers who assist us in operating our business:
(a) IT service providers who maintain our systems, website and databases.
(b) Communication service providers who facilitate email, telephone and video conferencing services for onboarding calls and programme delivery
(c) Payment processors if you proceed to purchase programme services.
3.3. We may disclose your personal data where we are legally required to do so by court order, regulatory authority or other legal obligation.
3.4. In the event of a merger, acquisition or sale of all or part of our business, your personal data may be transferred to the acquiring party, subject to appropriate safeguards.
3.5. All recipients of your personal data are bound by confidentiality obligations and are required to process your information only for the purposes for which it was shared and in accordance with applicable data protection laws.
3.6. We do not sell, rent or otherwise commercially exploit your personal data to third parties for their own marketing purposes.
4 - International Data Transfers
4.1. We may transfer your personal data to countries outside the United Kingdom in connection with the provision of the Thryve3 programme and our business operations
4.2. Such transfers may occur when we use third-party service providers for data hosting, payment processing, communication platforms, or other services necessary for programme delivery.
4.3. Where we transfer personal data to countries that have received an adequacy decision from the UK Government, we rely on such adequacy decision as the legal basis for the transfer.
4.4. For transfers to countries without an adequacy decision, we implement appropriate safeguards including:
(a) Standard contractual clauses approved by the UK authorities; or
(b) Other legally recognised transfer mechanisms under UK data protection law.
4.5. We ensure that all recipients of personal data in third countries are contractually obligated to provide an adequate level of protection for your personal data.
4.6. You may request further information about the safeguards we use for international transfers by contacting us using the details provided in this Privacy Policy.
4.7. In exceptional circumstances, we may transfer personal data without adequate safeguards where necessary for the performance of our contract with you or where you have explicitly consented to the transfer.
5 - Data Retention
5.1. We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, comply with our legal obligations, resolve disputes, and enforce our agreements.
5.2. Programme participants: Personal data of individuals who complete the Thryve3 programme will be retained for a period of 7 years following completion of the programme to enable us to provide ongoing support and comply with professional coaching standards.
5.3. Unsuccessful applicants: Personal data of individuals who do not proceed with the programme following the onboarding call will be retained for 2 years from the date of the onboarding call.
5.4. Incomplete applications: Personal data submitted through the signup form where no onboarding call takes place will be retained for 1 year from the date of submission.
5.5. We may retain personal data for longer periods where required by law, including but not limited to compliance with tax, accounting, or regulatory requirements.
5.6. When determining appropriate retention periods, we consider the nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process the data, applicable legal requirements, and our legitimate business interests.
5.7. At the end of the applicable retention period, personal data will be securely deleted or anonymised unless we are legally required or permitted to retain it for a longer period.
6 - Your Rights
6.1. You have the right to request access to your personal data that we hold, including information about the purposes of processing, categories of data, and recipients.
6.2. You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
6.3. You have the right to request that we delete your personal data in certain circumstances, including where it is no longer necessary for the original purpose or where you withdraw consent.
6.4. You have the right to request that we restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to processing.
6.5. You have the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit that data to another controller where processing is based on consent or contract and carried out by automated means.
6.6. You have the right to object to processing of your personal data where we rely on legitimate interests as the legal basis for processing.
6.7. You have the right to withdraw your consent at any time where processing is based on consent, without affecting the lawfulness of processing based on consent before its withdrawal.
6.8. You have rights in relation to automated decision-making and profiling, including the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects
6.9. To exercise any of these rights, please contact us using the details provided in the "Complaints and Contact" section of this Privacy Policy.
6.10. We will respond to requests within one month of receipt, though this may be extended by up to two months for complex requests.
6.11. We may request additional information to verify your identity before processing requests relating to your personal data.
7 - Cookies and Website Technologies
7.1. We use cookies and similar technologies on our website to enhance your browsing experience and facilitate the signup process for the Thryve3 programme.
7.2. Cookies are small text files stored on your device when you visit our website that help us recognise your browser and remember certain information about your visit.
7.3. We use the following types of cookies:
(a) Strictly necessary cookies that are essential for the operation of our website and signup form.
(b) Performance cookies that collect anonymous information about how visitors use our website to help us improve its functionality.
(c) Functional cookies that remember your preferences and choices to provide a more personalised experience.
7.4. We may also use web beacons, pixels, and similar tracking technologies to monitor website usage and email interactions.
7.5. Some cookies are placed by third-party service providers we use to deliver our services, including analytics providers and customer relationship management systems.
7.6. You can control and manage cookies through your browser settings, though disabling certain cookies may affect the functionality of our website and your ability to complete the signup process.
7.7. By continuing to use our website and completing the signup form, you consent to our use of cookies in accordance with this Privacy Policy.
7.8. For detailed information about the cookies we use and how to manage them, please refer to our separate Cookie Policy available on our website.
8 - Data Security
8.1. We implement appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction, damage, alteration or disclosure.
8.2. Our security measures include:
(a) encryption of personal data in transit and at rest where appropriate;
(b) regular security assessments and updates of our systems and software;
(c) access controls ensuring that only authorised personnel can access personal data on a need-to-know basis;
(d) staff training on data protection and security requirements;
(e) secure backup procedures and disaster recovery plans.
8.3. We regularly review and update our security measures to ensure they remain effective and proportionate to the risks associated with processing your personal data.
8.4. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you without undue delay in accordance with our legal obligations under UK GDPR.
8.5. We require any third parties who process personal data on our behalf to implement equivalent security measures and to process such data only in accordance with our written instructions.
8.6. While we take all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.
9 - Complaints and Contact
8.1. If you have any questions, concerns or complaints about this Privacy Policy or how we handle your personal data, please contact us at:
(a) Email: michael.chalmers@thryve3.com
(b) Post: Data Protection Officer, Thryve Pro Academy LTD, 3rd Floor, 86-90 Paul Street, London, England, United Kingdom, EC2A 4NE
8.2. We will investigate and respond to your query or complaint within one month of receipt.
8.3. You have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you are unhappy with how we have processed your personal data or handled your complaint.
8.4. You can contact the ICO at:
(a) Website: www.ico.org.uk
(b) Telephone: 0303 123 1113
(c) Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
9.5. You have the right to lodge a complaint with the ICO at any time, but we encourage you to contact us first so we can try to resolve any concerns directly.