PRIVACY NOTICE
 
Last updated June 2023
 
 
 
About The Conscious Leadership Co.

The website and services (Consultancy, Coaching, Consciously App and Psychometric Assessment) available at www.tclc.co, are owned and operated by The Conscious Development Group LTD (“the Group”, “TCLC”, “we”, “our, “us”), a company registered in England and Wales registration number (13257600)

For the purpose of the Data Protection Act 2018 ("the Act"), and the EU GDPR we are a Data Controller in common with our clients in respect of the user data we collect via the Consciously App and a Data Processor on behalf of our clients for the Psychometric services and are registered with UK’s data protection authority, the ICO, under Registration Number (ZB347794).
 

About This Privacy Notice

This Privacy Notice outlines how TCLC, Consciously App and the Psychometric Assessment handles your personal information. This includes the data being processed, how and why we collect it, how we use it and how it is protected.

We are providing you with information under the UK General Data Protection Regulation (UK GDPR), EU GDPR, and the UK Data Protection Act 2018.

TCLC takes your privacy seriously. We collect the minimum amount of information about you to be able to provide you and your employer with our services. 

This Privacy Notice describes the type of processes that may result in data being collected about you.

We use the information you and your employer provide (your ‘personal data’) for the purposes described below. 

This notice also explains what to do to if, for example, you want to make a complaint or ask us for your information.
 

Changes To Our Privacy Notice

Any changes to our Privacy Notice will be published on this page and will supersede the previous version of our Privacy Notice.

We will take reasonable steps to notify you of any changes to this notice, if you are on our mailing list.

However, we recommend reviewing this page when visiting the website if you are not in our mailing list.


Visiting the TCLC website

When visiting this website, we may collect information from you when you contact us, for example to book an appointment, or through cookies. 

Information about cookies in use for this site can be found on the cookie banner when you first visit.

You have control over which cookies should be used on your device and which ones to block via the visitor’s control panel launched by the banner.

We process cookies information from your device, specifically country, area and time of visit to track traffic to the site , site’s optimisation and performance.

Legal basis: Legitimate Interest and / or Consent provided by you via the cookie banner.


Discovery Call / Book an appointment

You can book an appointment via our website to learn more about our services. 
As part of the process we collect Name, email address, company name, telephone number and any contextual information you provide  which may help us to host an informative meeting.
We don’t share or sell this information.

Legal basis: Legitimate Interest


The Consciously App

If your employer has entered a contract with Us to provide employees with coaching services by leveraging the Consciously App, you will download the App to install it in your device.

For this scenario we are a Controller in Common with your employer and we will process your information by performing a contract with your employer and through our Legitimate Business Interest.

Our coaching services and Consciously App aim to deliver a tailored, personalised service. To ensure the best and most effective experience, it is necessary to process the following items of Personal Data:

– Names
– Business email address
– Job title
– Department / team
– Sentiment / mood checkpoints 
– Progression through content delivered as part of the coaching service

Your personal information is not sold to or shared with any unauthorised third party and is processed, including hosting, in the United Kingdom. 

Your Personal Data will be retained for no longer than is necessary for the purpose for which is processed, which includes a period after the delivery of coaching services to allow for audits and to assess the effectiveness of our services and as required by our contract with your employer; after this period expires, your information will be anonymised , so it ceases to be Personal Data and identify you, and kept in an anonymous and aggregated format for statistical purpose.

In the event you require to exercise the rights afforded to individuals under the EU and UK GDPR over your personal data relating to the Consciously App, the request must be submitted to your employer and / or The Conscious Development Group, since the parties are Co-Controllers  for this information.

For any such queries, please see contact details at the end of this policy

Legal basis: Legitimate Interest


Psychometric Assessment

If your employer has entered a contract with us to provide employees with a Conscious Leadership Psychometric Assessment, we will process your personal data on behalf of your employer.

For this scenario we are a Data Processor acting as instructed by and on behalf of your employer, the Data Controller. 

In the event you require to exercise the rights afforded to individuals under the EU and UK GDPR over your personal data relating to the Psychometric Assessment, the request must be submitted to your employer, which is Data Controller for this information.

Legal basis: Performance of Contract


Securing your data

TCLC takes your privacy seriously and applies adequate technical and organisational security measures to protect your personal data, as required by applicable laws. Keep an eye on this page for more details how we encrypt and secure your data
 
 
Your rights

Under the UK and EU GDPR, you are afforded the following rights
1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure
5. The right to restrict processing
6. The right to data portability
7. The right to object
8. Rights in relation to automated decision making and profiling.
 
You can find out more about your rights by visiting the Information Commissioner’s Office website:

The CCPA applies if a business has:

1. Has annual gross revenues in excess of twenty-five million dollars ($25,000,000), as adjusted pursuant to paragraph (5) of subdivision (a) of Section 1798.185.

2. Alone or in combination, annually buys, receives for the business’s commercial purposes, sells, or shares for commercial purposes, alone or in combination, the personal information of 50,000 or more consumers, households, or devices.

3. Derives 50 percent or more of its annual revenues from selling consumers’ personal information.
 
As such, please be aware that CCPA does not currently apply to The Conscious Development Group.

We actively monitor developments of Data Protection and Data Privacy regulations globally and will update this position should this be required.

We do not share your data with anyone for marketing purpose.
 

Data Transfers

We do not transfer your information submitted via the Consciously App or the Psychometric assessment outside the UK.


Sharing Personal Data 
 
We will not disclose your Personal Data to any third party, except with your employer who contracted us to provide this service, in accordance with this Privacy Policy.

We may allow other organisations to process Personal Data we hold about you in very specific circumstances as described below:

– If we, or substantially all of our assets, are acquired or are in the process of being acquired by a third party, in which case Personal Data held by us about our customers, will be one of the transferred assets.

– If we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings and sharing data is allowed under applicable laws. 

– For the prevention of crime, as may be required by law enforcement agencies and relating to specific requests and cases, with protections in place prescribed by the UK’s Data Protection Act and EU GDPR.

– We employ companies and individuals to perform functions on our behalf, such as technology partners and service hosting providers. Those parties are bound by strict contractual provisions with us and only have access to Personal Data needed to perform their functions and cannot use it for other purposes. Further, they must process the Personal Data in accordance with this Privacy Policy and as permitted by the Data Protection Act and the EU GDPR.

– Where you give us Personal Data on behalf of someone else, you confirm that you have provided them with the information set out in this Privacy Policy and that they have not objected to such use of their Personal Data. We reserve the right to verify the legitimacy of this aspect with periodic audits.
 

Contact
 
For any questions or to exercise your rights, as described in this policy, please email:
support@tclc.co