Privacy Policy​

Introduction

Your privacy is important to us. It is the policy of Change Aligned® to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, through the use of our Services and our Website; https://changealigned.com.

Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name and address), your devices, payment details, and even information about how you use a website or online service.

Our Website may contain links to third-party sites and services that are not covered by this Privacy Policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices.

We have drafted this Privacy Policy to be as clear and concise as possible. Please read it carefully to understand our policies regarding your information and how we will treat it. By using or accessing our Website, you agree to the collection, use and disclosure of information in accordance with the Privacy Policy. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Website. If you do not accept and agree with Privacy Policy, you must stop using our Website immediately.

You have the right to make a complaint at any time to the relevant Supervisory Authority for your jurisdiction, for data protection issues. If you are in the UK , this would be the Information Commissioners Office. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority, so please contact us in the first instance. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

If you have any comments on this Privacy Policy, please email them to enquiries@changealigned.com.

This Privacy Policy may change from time to time and your continued use of the Website is deemed to be acceptance of such changes, so please check periodically for updates.

This policy was last updated: December 2023.

Who We Are

Here are our details:

Our Website address is https://changealigned.com.

Our company name is Change Aligned®.

Our registered address is 71–75 Shelton St, London WC2H 9JQ.

Our nominated representative is Olga Valadon and can be contacted at enquiries@changealigned.com.

We respect your right to privacy and will only process personal information about you or provided by you in accordance with the Data Protection Legislation which for the purposes of this Privacy Policy shall mean: (i) the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR), (ii) the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (iii) any successor legislation to the UK GDPR or the Data Protection Act 2018, (iv) the EU General Data Protection Regulation (EU GDPR), and other applicable privacy laws.

What we may collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username, or similar identifier. When you email, phone, or otherwise, we may collect information such as your first name, last name, email address and phone number.
• Contact Data includes billing address, invoicing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments and other details of our Services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
• Profile Data includes your username and password, appointments made by you, your interests, preferences, feedback, and survey responses.
• Usage Data includes information about how you use our Website and Services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Interaction Data includes any information that you might provide in the course of our Services whether on our Website or through platforms provided by Third Parties.
• Cookies Data like many websites, we use “cookies” to enhance your experience and gather information about visitors and visits to our Website.  Please refer to our Cookies Policy for more information.
• Third Parties and Information we receive from other sources. We may receive information about you if you use any of the other platforms we use or through the Services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Website. We are also working closely with third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers, and search information providers) and may receive information about you from them.
• Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our Website and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

We may also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). 

Under the GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following bases applies:

• you have given consent to the processing of your personal data for one or more specific purposes. You may withdraw your consent at any time using the facilities we provide however this will not affect any use of your information that has already taken place;
• processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
• processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our Services, measures taken to operate our Services efficiently, marketing analysis, and measures taken to protect our legal rights and interests;
• processing is necessary for compliance with a legal obligation to which we are subject. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations.

If you provide personal information to us about another data subject, you are responsible for ensuring that you have their consent to provide that data for the uses set out in this Privacy Policy and for bringing this Privacy Policy to their attention.

Collection and Use of Information

We (or third-party data processors, agents and sub-contractors acting on our behalf) may collect, store, and use your personal information by way of different methods to collect data from and about you including:

• Direct interactions. You may give us your information by filling in forms via our Website or by corresponding with us by post, phone, email, social media, or on any similar technologies;
• Use a mobile device or web browser to access our content;
• Sign up to receive updates from us via email or social media channels;
• When you mention us on social media;
• Use any of our Services;
• Subscribe to our newsletter;
• Request marketing to be sent to you;
• Enter a promotion or survey; or
• Give us some feedback.

In addition to the above, we may use the information in the following ways:

• To personalise your Website experience and to allow us to deliver the type of content and product offerings in which you are most interested;
• To administer a promotion, survey, or other site feature;
• If you have consented to receive our e-mail newsletter, we may send you periodic e-mails. If you would no longer like to receive promotional e-mail from us, please simply follow the unsubscribe link or email us at enquiries@changealigned.com. If you have not opted-in to receive e-mail newsletters, you will not receive these e-mails. Visitors who register or participate in other site features such as marketing programmes will be given a choice whether they would like to be on our e-mail list and receive e-mail communications from us;
• Provide information, and Services that you request, or (with your consent) which we think may interest you;
• Carry out our contracts with you;
• Provide the relevant Services to you;
• Tell you our charges.

If you are already our customer, we will only contact you electronically about things similar to what was previously sold to you.

If you are a new customer, you will only be contacted if you agree to it.

We may keep a record of those links which are used the most to enable us to provide the most helpful information but we agree to keep such information confidential and you will not be identified from this information.

In addition, if you don’t want us to use your personal data for any of the other reasons set out in this section, you can let us know at any time by contacting us at enquiries@changealigned.com,  and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible Services to you.

In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the Services we can provide you if you don’t provide your personal data in these cases.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Where we need to comply with a legal or regulatory obligation, for example compliance with health and safety, tax, or other statutory obligations.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to our marketing communications or sending third party direct marketing communications to you via email, social media or text message. You have the right to withdraw consent to marketing at any time by contacting us at enquiries@changealigned.com, and we will either delete your data from our systems or move your data to our “unsubscribe list”. However, you acknowledge this will limit our ability to provide the best possible Services to you.

As already indicated above, with your permission and/or where permitted by law, we may also use your data for marketing purposes which may lead to us contacting you by email, social media and/or telephone with information, news and offers on our Services. We agree that we will not do anything that we have not agreed to under this Privacy Policy, and we will not send you any unsolicited marketing or spam. We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and other applicable privacy laws, as amended.

Cookies

All Cookies used by and on our Website are used in accordance with current UK Cookie Law.

We use cookies to distinguish users and improve our Website. Please look at our Cookie Policy for more cookie information.

Storage and Security of Your Personal Information

We may transfer your collected data to storage outside the EU or the UK. It may be processed outside the EU or UK to fulfil your order and to receive our Services and deal with payment. If we do store or transfer data outside the EU or UK, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EU or UK and under the GDPR. Your acceptance of this Privacy Policy shall be your consent permitting us to store or transfer data outside the EU or UK if it is necessary for us to do so.

We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We will notify you and any applicable regulator of a breach where we are legally required to do so.

By giving us your personal data, you agree to this arrangement. We will do what we reasonably can, to keep your data secure.

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification.

Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.

We will keep personal data for as long as is necessary which is usually the life of our relationship and up to a period of seven years after our relationship have ended. We may however be required to retain personal data for a longer period of time to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.

Disclosure of Personal Information 

We may disclose personal information to:

• third-party service providers for the purpose of enabling them to provide their services including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing providers, professional advisors, and payment systems operators
• our employees, consultants, contractors, and/or related entities
• our existing or potential agents or business partners
• to defend our claims
• where required under applicable laws
• third parties to collect and process data

Third parties we currently use and may access your data are:

• Strategy Tools: a global partner network of strategy consultants
• OCAI online: a global partner network of organisational culture consultants
• Google Analytics: a web analytics service offered by Google that tracks and reports website traffic
• Open Web Analytics: an open-source web analytics software that you can use to track and analyse how people use your web sites and applications
• Bluehost: the host of our domain https://changealigned.com
• WordPress: the web content management system used for our website
• Mailerlite: provider of the platform we use for marketing and sales
• CountingUp & Starling Bank: providers of the accounting software we use for payments and accounting records
• Lawbite: the online legal platform we use to receive legal support and expertise that allows us to fulfil our regulatory, contractual and other legal obligations and sign contracts
• Paperbell: the software we use for our coaching programmes which allows us to schedule appointments, take payments, sign contracts, and perform various tasks of client admin in relation to our coaching services
• Taxez: our accountants, responsible for preparation of our annual accounts and VAT returns
• Mobile services providers and platforms (e.g. WhatsApp), upon receiving your approval to use these communication methods for our interactions
• Virtual meeting platforms (e.g. MS Teams or Zoom)
• Social media platforms (e.g. LinkedIn) we use to disseminate our expertise and message  individuals and organisations 
• Stripe: a payments platform we use to accept payments
• Zoho cloud software suite used for our communication via email, online calls or to perform a number of activities such as project management or CRM
• Employees, consultants, contractors
• Providers of online leadership and team training materials, assessments and psychometric tools.

Your Rights 

When you submit information via our Website, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in this Privacy Policy).

Under the  GDPR, you have the right to:

• request access to, deletion of or correction of your personal data held by us at no cost to you;
• request that your personal data be transferred to another person (data portability);
• be informed of what data processing is taking place;
• restrict processing;
• to object to processing of your personal data; and
• complain to a supervisory authority.

You also have rights with respect to automated decision-making and profiling. However, this is not something that we undertake.

You have the right to ask us not to process your personal data for marketing purposes.

Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.

To enforce any of the foregoing rights or if you have any other questions about our Website or this Privacy Policy, please contact us at enquiries@changealigned.com.

Please note, that not all of these rights are absolute.

Changes to This Policy

At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy.

Terms and Conditions

Please also visit our Terms and Conditions establishing the use, disclaimers, and limitations of liability governing the use of our Website.

Your agreement

By using our Website and Services, by way of acknowledgment, you agree to our Privacy Policy.

Dispute Resolution

We will use our best efforts to negotiate in good faith and settle any dispute that may arise out of or relate to this Privacy Policy or any breach of it.

Any dispute shall not affect our ongoing obligations under this Privacy Policy.

This Privacy Policy and any dispute or claim relating to or connected with it (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of England and Wales and the courts of England and Wales are the only place where disputes or claims relating to or connected with this Privacy Policy (including non-contractual disputes or claims) may be decided.

Contact Us

For any questions or concerns regarding your privacy, you may contact us on enquiries@changealigned.com.