Our Privacy Policy.


 Our privacy policy provides information on how we, and any of our Associates, collect, use, secure, transfer and share personal data/information. Ingenious Performance helps organisations transform their performance, by working with their leaders, managers and staff. We provide tailored programmes specialising in subjects such as Leadership Development, Coaching, Communication and Facilitation.

1. Types of Information Collected.

Typically, Ingenious Performance may collect:

• First name
• Surname
• Business address
• Email address
• Phone numbers
• Cookies
• Information relevant to specific training programmes
• Financial information to enable the payment of Associates and Third Parties
• Digital images or video for specific training programmes


2. Methods of Collection

In the general conduct of business, Ingenious Performance collects information from:

• Clients
• Training Attendees
• Associates
• Employees

Such information will generally be collected directly via email, phone call, face to face
meetings or during a programme. We may also collect personal information through our

In addition, information may be submitted to us directly via several methods, including: email,
social media, by phone call, face to face meeting or through participation in a programme.
People may also agree to third parties disclosing personal data/information to us that those
third parties have collected.

We collect certain information by using automated means, such as cookies via our website.
The information we collect in this manner may include: IP address, browser type, operating
system, referring URLs and information on actions taken or interaction with our digital assets.

We may use third-party web analytics services on our websites. The analytics providers that
administer these services use technologies such as cookies and web beacons to help us analysehow visitors use our websites.

“Your Rights and Choices” section of this Privacy Notice specifies your ability, to opt out or
limit the usage of the information collected.


3. Purposes of Collection

Generally, we will collect, use and hold personal information for the following purposes:

• The successful delivery of training programmes for our clients
• Processing payments / financial transactions
• To operate, monitor, evaluate and improve our services and website
• To develop new programmes and services


4. Lawful basis of processing

Ingenious Performance processes personal information under the following lawful bases:

• Performance of a contract: where someone enters into a contract with Ingenious
Performance and we need to process their information as part of this contract

• Legitimate interests: the legitimate interest of Ingenious Performance is the
successful delivery of training programmes for our clients.

• Consent: where we process information under consent we will seek clear and
unambiguous consent from the person concerned, prior to processing any personal


5. Information We Share

We do not sell or otherwise disclose personal information, except as described in this Privacy
Notice or as indicated via the consent process at the time the data is collected.

We may share the information we collect with:

• Vetted Associates who deliver training programmes on behalf of Ingenious

• Formally contracted service providers to perform services on our behalf e.g. profiling
or data analysis that forms part of a training programme. You will always be asked to
give Consent prior to us providing your data to any Service Provider.

We contractually require our Associates and service providers to safeguard the privacy and
security of personal information they process on our behalf and authorise them to use or
disclose the information only as necessary to perform services on our behalf or comply with
legal requirements.

Additionally, we may share personal information, if required legally, to prevent harm of
financial / reputation loss, for investigation of suspected or actual fraudulent or illegal


6. How long do we keep information for?

Ingenious Performance stores personal information only for as long as it is necessary for the
fulfilment of the purpose for which the personal information was collected, unless otherwise
required by applicable law.

We take measures to destroy or permanently anonymise personal information as required by
law or if the personal information is no longer required for the purpose for which we collected


7. International Data Transfers

Ingenious Performance may transfer personal information to recipients in countries other
than the country in which the information was originally collected e.g. if delivering training
programmes for a client based in the UK and other countries. Those countries may not have
the same data protection laws as the country in which the information was initially provided.
When we transfer information to other countries, we will protect that information as
described in this Privacy Notice or as otherwise disclosed at the time the data is collected.


8. Direct Profiling

Direct profiling is engaged for fair and lawful purposes. This includes legal reporting as may
be required by applicable laws, regulations, policies / standards or requested by any judicial process or governmental agency having or claiming jurisdiction over Ingenious Performance
or its affiliates; including, but not limited to:

• Benchmarking employees: appraisals, performance, bonus payments, disciplinary actions, improvement plans, promotions and awards.

• Background checks for existing and new employees, Associates, business partners.


9. Rights and Choices

Everyone can exercise choices about the personal information collected by Ingenious
Performance, how we use that information, and how we communicate with them.

Everyone has the right to:

• Obtain confirmation that we hold personal information about them

• Request access to and receive information about the personal information we
maintain about them

• Receive copies of the personal information we maintain about them

• Update and correct inaccuracies in their personal information

• Object to the processing of their personal information

• Have the information blocked, anonymised or deleted

• Opt out collection of personal information by automated means e.g. when visiting our
website by using the Cookie Consent tool displayed in the website (the browser used
may provide options on how to opt out of receiving certain types of cookies).

• Withdraw any consent previously provided to us.

• If we process personal data/information under legitimate interest an objection can be
made at any time on legitimate grounds, to the processing of personal

To exercise these rights, please contact us at sayhi@ingeniousperformance.com


10. How to Contact Us / Complaints and Feedback


• Make a complaint about a breach of personal information, applicable privacy laws /
principles or report a concern about Ingenious Performance privacy practices

• Access and/or update information or preferences you provided to us, please e-mail us at: sayhi@ingeniousperformance.com, call +44 7794 354 724 or write to us at:

Ingenious Performance
The Barn
Whatley Court Yard
Whatley, Frome
Somerset, BA11 3LA


11. How We Protect Personal Information

The security of personal date/information is very important, and Ingenious Performance is committed to protecting the information we collect. We maintain administrative, technical and physical safeguards designed to protect the personal information provided (or that we collect) against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.


12. Updating this Privacy Statement

We will update this statement as required, so we recommend reviewing this statement at
regular intervals. Where we undergo substantial changes to our privacy statement we will endeavour to inform you directly about these changes.

May 2018