OPTIMAL PEOPLE LIMITED

DATA PRIVACY POLICY

Welcome to Optimal People Limited’s data privacy policy.

Optimal People Limited (“Optimal People” or “We”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or contact us via email or phone and share your data with us. It also tells you about your privacy rights and how the law protects you.

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Optimal People collects and processes your personal data through your use of this website, including any data you may provide through this website when you complete any forms on our site or send any information to us as well as any data that you provide to us in person, via email or on the phone. It is important that you read this privacy policy so that you are fully aware of how and why we are using your data.

We do not knowingly collect data relating to children and do not use any data relating to children.

We are the controller and responsible for your personal data. If you have any questions on this policy, including any questions about this policy or how we handle your personal data, or if you wish to exercise your legal rights under Your legal rights, please contact us using the details set out below:

Your duty to inform us of changes

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.

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 policy of every website you visit. Such third parties may include:

• Service providers acting as processors who provide IT and system administration services, such as Microsoft, and Netlify and Cloudflare, which host and deliver this website;
• Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services; or
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

The data we collect about you

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:

• Identification Data includes full name, date of birth, gender, nationality, marital status, next of kin, any dependants and emergency contacts, photographs, video and/or audio recordings, and other media captured during programme activities.
• Contact Information includes address, email address and phone number.
• Financial Information includes payment details such as bank account and payment card details (if applicable).
• Employment Details includes professional background, qualifications, skills, employment history, previous and current employers.
• Technical Data includes internet protocol (IP) address, 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.
• 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.
• Sensitive Personal Data includes dietary preferences and access/mobility requirements (which may constitute special category data – see Special Categories or Personal Data below).

We may collect any Special Categories of Personal Data about you (for example health information relating to dietary or accessibility requirements) to accommodate your needs. We will only do so if you provide us with explicit consent to process such data.

We acknowledge that for participants, you will be able to view personal data of other participants on our programmes, including Identification Data and Contact Information for the purpose of setting up group chats. Should you not wish for such data to be disclosed to other participants, you have the right to opt-out.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identification Data and Contact Information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes processing personal data for the purpose of:
• providing and maintaining our services to you;
• notifying you about changes to our services;
• providing support to participants, mentors and other personnel we come into contact with;
• gathering analysis or valuable information so that we can improve our services;
• monitoring the usage of our services;
• detecting, preventing and addressing technical issues; and
• providing you with news, special offers and general information about other services which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data using server logs and Cloudflare Web Analytics, a visitor counter that does not use cookies. Our website sets cookies only if you sign in with an access code, to keep you signed in; see our Cookie Policy.
• Access codes. If we give you an access code to view the private areas of our website (such as our coaching faculty, our CPO Accelerate mentors or our alumni area), we keep a record of when you sign in and of the profiles you view, shortlist or ask to be introduced to, so that our team can arrange the right introductions. Your code and your IP address are stored only in scrambled form.

How we use your personal data

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 it is necessary for our recognised legitimate interests (RLIs). These are different to legitimate interests. RLIs apply where there are public interest reasons for processing (such as preventing or detecting crime, safeguarding individuals, responding to emergencies, supporting national or public bodies when they confirm it is necessary for their official functions). RLIs are legally recognised within data protection law. Where we rely on an RLI, we will ensure the use is strictly necessary and only use or share the minimum data required.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds, we are relying on to process your personal data where more than one ground has been set out in the table below:

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

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 contacting us at any time.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Data transfer outside of the UK and EEA

Some of our external parties are based outside the UK and EEA so the processing of your personal data will involve a transfer of data outside the UK and EEA. For example, we may transfer your personal data to service providers that carry out certain functions on our behalf. It may also be processed by staff operating outside the UK and EEA who work for us or for one of our suppliers. If your personal data is transferred to, stored at, or otherwise processed in a country or territory outside the UK and EEA, and that country or territory has not been recognised as providing an adequate level of data protection, we will put in place additional safeguards to protect your personal data, based on specific contracts approved for use in the UK and EEA which give personal data the same protection it has in the UK and EEA. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and EEA.

Disclosures of your personal data

We may share your personal data with third parties for the purposes set out in the table Purposes for which we will use your personal data above. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Data security

Unfortunately, the transmission of information via the internet is not completely secure. Although we will take reasonable steps to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, 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 request that our third-party contractors and site service providers follow similar standards of security and confidentiality.

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

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

No fee usually required

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. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Use of Artificial Intelligence (AI) Tools

We may use artificial intelligence (AI) tools to process personal data. These AI tools are employed to enhance our products by analysing data patterns, improving customer experience, and ensuring the security of our systems. The purposes for which AI tools will be used include, but are not limited to:

• Data Analysis and Insights: AI tools will analyse data to provide insights that help us improve our products and tailor them to customer needs.
• Security and Fraud Prevention: AI tools will be used to detect and prevent fraudulent activities, ensuring the safety and integrity of our systems.
• Personalisation: AI tools will assist in personalising customer experiences by recommending content or products based on customer preferences and behaviour.

We are committed to ensuring that the use of AI tools complies with all applicable data protection laws, including the UK General Data Protection Regulation, the Data Protection Act 2018, the Data (Use and Access) Act 2025 and other relevant legislation. We implement appropriate technical and organisational measures to safeguard personal data and uphold individuals' rights.

Glossary

Consent means when you freely provide a specific, informed and unambiguous indication of your wishes through a written statement or clear affirmative action, inter alia, to being contacted by our marketing teams, or being asked to participate in a market research project which would be collected on our behalf by us or our third-party recruiters.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Recognised Legitimate Interest means a specified purpose for handling personal data that is in the public interest and covers situations, such as crime prevention, public security, national security or defence, safeguarding, emergencies or sharing personal information to help other organisations perform their public tasks or official functions. Although there is no requirement for us to assess whether a person’s rights, freedoms or interests outweigh the recognised legitimate interest, we must consider whether the activity we want to do is necessary.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Data Protection Complaints

We are committed to protecting your personal data and take all complaints regarding the handling of your personal data seriously. This policy outlines the procedure for managing complaints.

You have the right to complain to us if you are dissatisfied with the way we handle your personal data, including but not limited to insecure handling of your personal data, failing to meet data protection rights, such as subject access requests, or unfair or unlawful processing of your personal data. You can make a complaint by emailing us at hello@optimalpeople.co.uk or writing to us at Ashbourne House, The Guildway, Old Portsmouth Road, Guildford, Surrey GU3 1LR.

When making a complaint, please include your full name, contact details and full details of the complaint. We will acknowledge receipt of your complaint within 30 days, and your complaint will be investigated by us. A substantive response will be provided to you without undue delay.

For the purpose of improving our services, we will keep records of all data protection complaints, including the nature of the complaint and the actions taken.

We are registered with the Information Commissioner’s Office (ICO), the UK’s supervisory authority, with registration number ZB904525. If you are dissatisfied with our response, you have the right to complain directly to the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Changes to the privacy policy

We keep our privacy policy under regular review. This version was last updated on September 2026.