Privacy Policy

Positivity in Practice is a trading name of Nickleby Consulting Ltd (Company No. 12164548).

We are the controller of your personal data. For more information on controllers and their responsibilities please see ICO guidance on data protection principles, definitions, and key terms.

This privacy notice tells you what to expect us to do with your personal information.

Contact details
What information we collect, use, and why
Lawful bases and data protection rights
Where we get personal information from
How long we keep information
Who we share information with
Sharing information outside the UK
Cookies and tracking
How to complain

Contact details

Email: sarah@positivityinpractice.com

What information we collect, use, and why

We collect or use 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)
Usage data (including information about how you interact with and use our website, products and services)
Records of meetings and discussions
Account access information
Website user information

We collect or use the following personal information for the operation of client or customer accounts:

Names and contact details
Addresses
Purchase or service history
Account information, including registration details
Technical data, including information about browser and operating systems

We collect or use the following personal information for information updates or marketing purposes:

Names and contact details
Profile information
Marketing preferences
Website and app user journey information
IP addresses

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.

Our lawful bases for collecting or using personal information for the operation of client or customer accounts 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.

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.

Where we get personal information from

Directly from you
Suppliers and service providers

How long we keep information

We retain information for only as long as is necessary; programme participation data for 24 months after the programme ends, marketing data up to 24 months of inactivity, or until you unsubscribe, and payment data for 6 years, as required by law.

Who we share information with

We share information with the following data processors:

Brevo

This data processor does the following activities for us: They provide our CRM and email marketing services, including managing contact lists.

Passion.io

This data processor does the following activities for us: They host our online programme content and community, and manage user access.

OpenAI (ChatGPT Team)

This data processor does the following activities for us: They provide AI tools used to support coaching exercises and course activities.

Microsoft 365

This data processor does the following activities for us: They host and manage our email communications and cloud-based business tools.

GoDaddy

This data processor does the following activities for us: They host our website and support website functionality.

Stripe

This data processor does the following activities for us: They process online payments for our services.

Zoom

This data processor does the following activities for us: They host our online meetings.

Sharing information outside the UK

Where necessary, our data processors will share personal information outside of the UK. When doing so, they 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.

Organisation name: Brevo

Category of recipient: CRM and email marketing services

Country the personal information is sent to: France / EU (plus possible global subprocessors)

How the transfer complies with UK data protection law: Adequacy Regulations

Organisation name: Passion.io

Category of recipient: Online course and training platform