Privacy Policy

1.   INTRODUCTION  

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.aimhigherleadership.com

 By providing us with your data, you warrant to us that you are over 13 years of age.

 Aim Higher Leadership Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details

Our full details are:

Aim Higher Leadership Ltd

Email address: info@aimhigherleadership.com

Postal address: Willow House, Silk Mill Lane, Cheltenham, GL54 5HZ

Telephone: 01242 650094

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@aimhigherleadership.com

2.  WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT 

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

·        Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

·        Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

·        User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

·        Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

·        Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

·        We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

Sensitive Data

We require your explicit consent for capturing and processing sensitive data in order to deliver our services/products to you (for example writing and keeping on file notes from coaching sessions), we will ask you to provide this consent when you start working with us.

If you choose to disclose any sensitive personal data (data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health etc see www.ico.org.uk for further information about sensitive data) to us during our sessions with you,  we will use your sensitive personal data for the purposes of providing our services to you or if we need to comply with a legal obligation. Our legal ground of processing this data is your explicit consent.

Group sessions may result in collective information about the group being captured (e.g. objectives, projects, strategies) This information will be retained and protected in line with our privacy policy but no individual sensitive data will be retained at these events (with the exception of 360 feedback/psychometric reports which will only be undertaken if the individual consents to this, see below)

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at info@aimhigherleadership.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

Automated Decision-Making and Profiling

We may use automated processes to analyse personal data, including to calculate and produce 360-feedback or psychometric profiles, summarise feedback, categorise survey responses and identify themes or patterns. These processes may be carried out by us or by external assessment or technology providers.

The systems apply predefined scoring methods or analyse survey responses and feedback to produce scores, categories, themes or summaries. The outputs support coaching, feedback and service improvement and are reviewed and interpreted by an appropriately qualified person.

These processes do not have a legal or similarly significant effect on you and do not materially determine your rights, opportunities or access to services. Where appropriate, we ensure that human oversight is applied. 

Our lawful grounds for processing this data are the performance of a contract and/or our legitimate interests in providing and improving our services. Where special-category personal data is processed, we will obtain your explicit consent or identify another applicable condition permitted by law.

3.  HOW WE COLLECT YOUR PERSONAL DATA

We collect personal data directly from you when you contact us, complete forms, engage our services or communicate with us.

We may also receive your contact details from clients or other individuals who believe our services may be relevant to you, and from publicly available professional sources such as LinkedIn and Companies House. 

4. MARKETING COMMUNICATIONS 

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.

We have no intention of sharing your personal data with any third party for marketing purposes but if this situation ever arose, we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at info@aimhigherleadership.com at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc. 

5.  DISCLOSURES OF YOUR PERSONAL DATA  

We may have to share your personal data with the parties set out below:

•        Service providers who provide IT and system administration services.

•        Associate Leadership Coaches who provide services for Aim Higher Leadership Ltd

•        Professional advisers including lawyers, bankers, auditors and insurers

•        Government bodies that require us to report processing activities.

•        With coach supervisors as part of our professional coaching supervision

•        Providers of 360-feedback, psychometric assessment, survey-analysis and related technology services, including The Unify Partnership and The Leadership Circle (see section 2 above)

•        Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6.  INTERNATIONAL TRANSFERS  

We are subject to the provisions of the UK General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the UK, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

•        We may transfer your personal data to countries that the relevant regulatory authorities in the United Kingdom have approved as providing an adequate level of protection for personal data by; or

•        If we use US-based providers that are part of a UK regulator approved privacy framework, we may transfer data to them, as they have equivalent safeguards in place; or

•        Where we use certain service providers who are established outside of the UK, we may use specific contracts or codes of conduct or certification mechanisms approved by the United Kingdom regulators which give personal data the same protection it has in the UK.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. 

7.  DATA SECURITY  

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees, associates and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

8.  DATA RETENTION  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.  YOUR LEGAL RIGHTS  

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

If you are within the UK, you can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at info@aimhigherleadership.com

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

When responding to a request to access your personal data, we are only required to carry out searches that are reasonable and proportionate in the circumstances (as now expressly recognised in the Data (Use and Access) Act 2025). This means we will take into account factors such as the nature of the information sought, the context in which it is held, any difficulty involved in locating it and the potential benefit to you of receiving it.

We try to respond to all legitimate requests within one month of receiving the request (or, where applicable, of receiving the identity verification information or clarification we have asked for - the response period is paused, or "stopped", while we wait for that information, in line with the Data (Use and Access) Act 2025).

Occasionally it may take us longer than one month if your request is particularly complex or you have made a number of requests, in which case we may extend the response period by up to a further two months. We will notify you within one month of receiving your request if an extension is needed and explain why.

10.  HOW TO COMPLAIN

If you have a complaint about how we handle your personal data, we ask that you contact us first so that we can try to resolve it for you.

You can submit a data protection complaint to us by:

·        emailing us at info@aimhigherleadership.com

We will acknowledge your complaint within 30 days of receiving it. We will investigate your complaint without undue delay, keep you informed of our progress, and communicate the outcome to you clearly with sufficient detail for you to understand how we reached our conclusion.

If you are within the UK and are not satisfied with our response, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

 11. THIRD-PARTY LINKS  

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 12. COPYRIGHT NOTICE

All design, text, graphics and arrangement thereof are the copyright of Aim Higher Leadership Ltd or of other copyright owners. Any unauthorised reproduction of the contents of this site without the prior written permission of Aim Higher Leadership Ltd is strictly prohibited.

AI Addendum to Privacy Notice

Aim Higher Leadership Ltd.

Privacy Notice for Use of AI Technology

Introduction

We respect your privacy and are committed to protecting your personal data. This privacy notice explains how Aim Higher Leadership Ltd processes personal data when using AI tools and ensures compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This notice is supplemental to our Privacy Notice that you can view at https://aimhigherleadership.com/privacy-policy

 AI Tools in Use

AI refers to a broad category of technologies and methods designed to emulate human thinking and tackle complex challenges. We use AI tools to support business operations, including business strategy, marketing, data analysis, and continuous improvement. Specifically, if we are contracted to undertake 360 feedback we may create custom AI models to analyse this 360 degree feedback data and generate coaching reports. These tools largely process anonymised client data but may process some personal data derived from client organisations to improve efficiency, enhance accuracy, and optimise service delivery .  In using the AI tools, we ensure that all data is handled in compliance with applicable data protection laws.

What Data Do We Collect?
In using the AI tools, we may process the following types of personal data:

 How Do We Collect Your Data?
We collect data directly from you, such as through:

 Why Do We Use Your Data?
We process personal data to:

 What is the Lawful Basis for Processing?

Our lawful ground for processing personal data is primarily based on the necessity to perform a contract with our clients. When we carry out 360 feedback, we will have a contract in place with the client that outlines the terms of the feedback process. This contract serves as the legal basis for processing any personal data involved in the feedback.

In addition, we may also rely on Legitimate Interests as a lawful ground for processing, as we aim to enhance our service delivery and business efficiency. If we need to process special category data we will ensure that we do so in a compliant way which may include obtaining your explicit consent to such processing.

How We Protect Your Data

Third-Party Involvement

We use Chat GPT as a data processor. We have agreements in place with such data processors to ensure the privacy of your personal data. Data submitted through our ChatGPT account is not used to train OpenAI’s models. For details on their privacy standards, refer to their https://openai.com/en-GB/policies/row-privacy-policy/

Changes to This Notice

We may update this notice from time to time. Please check this page periodically for updates.

Contact Information

For queries regarding this notice, contact:
Stuart Pickles

info@aimhigherleadership.com