Privacy Policy

Effective date 10 July 2025

INTRODUCTION

Glass Box Thinking Ltd (“we”, “us”, “our”) is committed to safeguarding the privacy and personal information of our clients and contacts in line with all applicable privacy and data protection laws customer privacy notice.  This privacy notice tells you what to expect us to do with your personal information.

This Privacy Notice explains how we may collect, use, process, share, and store personal information about you, including through designated third-party service providers, and the choices that are available to you regarding this information. Please read this Privacy Policy carefully to understand our views and practices regarding your personal information and how we will treat it.

In addition to information kept in hardcopy, this Privacy Policy also applies to Company-related websites, digital documents and online applications.

WHAT INFORMATION DO WE COLLECT ABOUT YOU AND WHY?

Information you give us

We only collect information where:

·      You have provided this either as a direct client,  

·      You have expressed an interest in our organisation;

·      You have subscribed to our newsletter or signed up to our mailing list.

The types of information that you may give us vary depending our relationship with you. For example, you may have provided your contact details to us at a networking event, through connecting on LinkedIn or from a personal meeting. If you are a client you may have also provided personal profiling, performance and development information.

The information you may give us could include categories such as, but not limited to, your name, work or personal address, e-mail address, phone number, gender. If we have worked with you we may hold psychometric data, notes from coaching sessions or development sessions.

We may also collect or use some or all of the following information to provide and improve products and services for clients:

·       Names and contact details

·       Addresses

·       Occupation

·       Payment details (including card or bank information for transfers and direct debits)

·       Transaction data (including details about payments to and from you and details of products and services you have purchased)

·       Usage data (including information about how you interact with and use our website, products and services)

·       Video recordings

·       Audio recordings (eg calls)

·       Records of meetings and decisions

·       Website user information

Information we receive from other sources 

We do not receive information from other sources, other than sometimes feedback from your employer, manager, or employees as part of the development work we may be doing with yourself.

HOW DO WE USE THE INFORMATION ABOUT YOU?

We only use your information to provide you with services you have engaged with, e.g. as a coachee or programme participant, newsletter subscriber etc.

We delete the personal data we hold which is linked directly to delivering our services, e.g. coaching notes, psychometric test results, development plans etc., after a suitable period of time.

We may use your contact information to occasionally provide you with our latest blog and information about goods or services we feel may interest you.

If you have subscribed to our newsletter or mailing list we will Each time you receive a communication from us, you always have the option to change your mind and unsubscribe.

Additionally, if at any time you wish us to stop using your information for any the above purposes, please contact us and we will do so as soon as it is reasonably possible.

HOW DO WE STORE AND KEEP INFORMATION SECURE?

We take measures to ensure the security of all information we hold, for example by restricting access, ensuring password protection on all digital data, removing identifying information and having secure storage facilities. We only partner with digital information services who comply with GDPR requirements. E.g. Psychometric houses, CRM providers, E-mailing services.

HOW DO WE SHARE YOUR INFORMATION? 

We place great importance on confidentiality – it is critical to the type of work that we do. We will not sell any personally identifiable information collected by us to any third party.

We may share your data with:

– Service providers (e.g. hosting, email delivery, CRM support)
– Third-party platforms integrated into your account (e.g. Stripe, WhatsApp, Funnel Sketchers Ltd)

We are not responsible for how third-party platforms use your data. Their use is governed by their respective privacy policies.

Of course, we will always abide by the law of the land and if information is legitimately requested by the Government or one of their agencies, we will comply with any such request.

Sharing information outside the UK

Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)

LAWFUL BASES AND DATA PROTECTION RIGHTS

 Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website.

Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.

Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.

Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.

Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.

Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.

Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

HOW TO COMPLAIN

 If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO www.ico.org.uk

The ICO’s address:           

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

HOW TO CONTACT US

If you have any questions or would like to exercise your rights, please contact us at:

Glass Box Thinking Ltd

Suite 6, 2 Place Farm,

Wheathamstead,

Hertfordshire, AL4 8SB, GB

Email: [email protected]