Privacy Policy

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The Company is a consultancy business which provides coaching and training services to its clients. The Company must process personal data (including special categories of personal data) so that it can provide these services – in doing so, the Company acts as a data controller.

You may give your personal details to the Company directly, such as on sending an inquiry via our website, or we may collect them from another source such as engagement with our LinkedIn page. The Company must have a legal basis for processing your personal data. For the purposes of providing you with consultancy services and/or information relating to training support relevant to you, we will only use your personal data in accordance with this privacy statement. We will comply with current data protection laws at all times.

1. Collection and use of personal data

Purpose of processing and legal basis

The Company will collect your personal data (which may include special categories of personal data) and will process your personal data for the purposes of providing you with coaching and training consultancy services. This includes for example, contacting you about training sessions we have created for you when you have engaged us to do so, contacting you about proposed new coaching and training offerings, contacting you with updates on the progress of training programmes you have engaged us to deliver, or similar.

On some occasions we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

We must have a legal basis to process your personal data. The legal bases we rely upon to offer our consultancy services to you are:

1. The processing is necessary to perform a contract with you or take steps before entering into a contract with you.
2. The processing is necessary to comply with our legal and regulatory obligations.
3. You have given us your consent for us to process your personal data for a specific purpose.
4. The processing is necessary for our legitimate interests provided your interests and fundamental rights do not override those interests.
5. The processing is necessary to protect your vital interests (or someone else’s interest).
6. The processing is needed in the public interest.

Legitimate interest 

This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

• Managing our database and keeping partner company records up to date;
• Providing consultancy services to recruitment/sales consultants and companies;
• Contacting you to seek your consent where we need it;
• Giving you information about similar products or services to those that you will have used from us recently;

Statutory/contractual requirement

The Company has certain legal and contractual requirements to collect personal data (e.g. to enter into a contract with you, delivering consultancy services either to your business or to individuals within it).  Our clients may require this personal data, and we may need your data to enter into a contract with you. If you do not give us the personal data we need to collect In order to comply with our statutory and legal requirements, we may not be able to continue to provide consultancy services to you.

1. Categories of Personal Data Collected

The Company may collect and process the following categories of personal data about you:

Personal Data:

• Name, address, mobile number, and email address
• Company Registration Information
• Name, job title, and relevant performance information of employees receiving training
• Tax information: tax status, tax residency, and tax identification number
• Contact details: home and/or business address, phone number, email
• Employment information: relevant qualifications, employer or employee name, and remuneration
• Financial data: source of wealth, asset information, bank details, credit history
• Visit records: details of visits to our offices, premises, and website
• Marketing preferences and other communication preferences
• Information you provide during correspondence, which may include data about individuals connected to you

Special Categories of Personal Data:

• Health-related information, including details of any disability
• Criminal conviction(s)
• In certain cases and to meet legal or regulatory obligations (e.g., Anti-Money Laundering and counter-terrorist financing regulations), data revealing racial or ethnic origin, political opinions, medical history, affiliations, or criminal records
• Where we process special category data, we do so under Article 9(2)(b) (employment obligations), (g) (substantial public interest), or (a) (explicit consent), as appropriate.

1. How We Collect Personal Data

We ordinarily collect personal data directly from you or your authorised representatives through:

• Forms and documents required to provide our consultancy and related services
• Agreements or contracts entered into with Thrive Pathways
• Information gathered during due diligence processes to meet our legal and regulatory obligations
• Communications via phone, email, written correspondence, or other means

We may also collect personal data from third parties, including:

• Entities in which you or a connected party have an interest
• Your advisers or authorised agents
• Current or former employers and referees
• Banks and financial services providers
• Credit reference agencies and financial crime databases, to comply with regulatory requirements
• Information from our website (including cookies and IP addresses) and email traffic data (e.g., headers used for analysing network activity and managing relationships)
• Publicly accessible sources such as LinkedIn 
• A former employer or employee
• Recruitment platforms or third-party sources

Please note, there may be multiple legal grounds for our processing of your data, and several may apply simultaneously.

1. Recipients of Your Data

Thrive Pathways may share your personal and/or special category data with the following recipients, where appropriate:

• Your employer and manager from whom we may request information relating to your performance and career development
• Your employee(s) where you engage us in a contract to deliver our coaching, training or other consultancy service to 
• Auditors and compliance professionalsreviewing our operations for adherence to relevant legislation and good practice guidance

1. Purpose of Processing 

Your personal data may be processed for the purposes set out below:

• providing the services;
• conducting financial screening;
• communicating with you in the provision of the services or to answer your requests;
• monitoring and recording telephone and electronic communications and transactions (i) in order to improve service delivery and (ii) for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution of any unlawful act (or omission to act);
• releasing personal data to banks or other financial institutions;
• enforcing or defending our legal and contractual rights or those of third party service providers;
• complying with regulatory and/or legal obligations;
• collecting, processing, transferring and storing of customer due diligence data, source of funds information and verification data and conducting checks and sanctions screening; and
• liaising with or reporting to financial services regulators or other public authorities or governmental bodies we are required to cooperate with, report to and or with whom we decide or deem appropriate to cooperate.

1. Sharing of Personal Data  

We may share your personal data with our group companies and third parties (including lawyers, auditors, other service providers who perform services on our behalf, and financial, taxation, regulatory or judicial authorities upon request and to the extent permitted by law).

• Where we share your personal data, we require those third parties to put in place adequate measures to protect it.
• In sharing your personal data, we may transfer it to other countries.
• We may transfer your personal data outside of the European Economic Area (the EEA) to countries that provide an adequate level of protection or to non-EEA countries that have not been recognised as adequate by the European Commission. If on the latter basis, we will ensure it is protected and transferred in a manner consistent with legal requirements (such as by using model contractual clauses, binding corporate rules or other data transfer mechanisms).

For our core activities we are using the following technology service providers:

• Microsoft – Microsoft collaborative services, including email server hosting;
• Adobe – document management and electronic signing

1. Data retention

The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time.

Where the Company has obtained your consent to process your personal data, we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data.

1. Your rights

Please be aware that you have the following data protection rights:

• The right to be informed about the personal data the Company processes on you;
• The right of access to the personal data the Company processes on you;
• The right to rectification of your personal data;
• The right to erasure of your personal data in certain circumstances;
• The right to restrict processing of your personal data;
• The right to data portability in certain circumstances;
• The right to object to the processing of your personal data that was based on a public or legitimate interest;
• The right not to be subjected to automated decision making and profiling; and
• The right to withdraw consent at any time.

Where you have consented to the Company processing your personal data, you have the right to withdraw that consent at any time by contacting the company Director, Magella Quest, on the details above. Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.

There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.

If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.

 You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.

1. Inaccurate Information and/or Need for Amendment 
   Please let us know as soon as possible if any of the personal data you have provided to us changes. If you do not provide us with accurate information or fail to update us with updated information when it changes, this may affect us being able to provide services. Failure to provide information to us if required for due diligence or other legal requirements may result in us not being able to provide services on a timely basis (or at all).
2. Login Files

We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

1. Links to external websites

The Company’s website may contain links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website. 

1. Sale of business

If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business. Where the sale of the business results in the transfer of your details to a different data controller we will notify you of this.

1. Data Security

The Company takes every precaution to protect users’ information through firewalls, browser certification technology, encryption, limited access and use of passwords.

Only employees who need the information to perform a specific job (for example, consultants, our accounts clerk or a marketing assistant) are granted access to your information.

The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/the Internet.

If you share a device with others, we recommend that you do not select the “remember my details” function when that option is offered.

In the event of a personal data breach, we will assess the risk to your rights and freedoms and, where necessary, report this to the ICO and inform you without undue delay.

If you have any questions about the security at our website, you can email Magella Quest on magella@thrive-pathways.co.uk.

1. Changes to this privacy statement

We will update this privacy statement from time to time. We will post any changes on the statement with revision dates. If we make any material changes, we will notify you.

1. Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Magella Quest on magella@thrive-pathways.co.uk.

You also have the right to raise concerns with the Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/make-a-complaint/, or any other relevant authority should your personal data be processed outside of the UK and you believe that your data protection rights have not been adhered to.