Privacy Policy

2. What personal data we collect

The information we collect depends on how you interact with us.

Information you provide directly:

• Your name.
• Email address.
• Telephone number.
• Business or organisation name.
• Job title or professional role.
• Billing and invoicing information.
• Information about your business, project, goals or challenges.
• Information provided through contact forms, questionnaires or diagnostic tools.
• Event booking information.
• Dietary, accessibility or other event requirements.
• Meeting preferences and appointment details.
• Correspondence and records of our communications.
• Feedback, testimonials or survey responses.
• Marketing preferences.

Please avoid providing sensitive personal information unless it is genuinely necessary for us to provide the relevant service or make appropriate event arrangements.

Professional information obtained from public sources

We may collect limited professional information about business owners, directors and other business contacts from publicly accessible sources.

This may include:

• Your name.
• Job title, directorship or professional role.
• Company or organisation name.
• Business email address.
• Business telephone number.
• Company type and registered status.
• General information about the business and its publicly promoted services.
• Publicly announced business developments, such as growth, recruitment, relocation or service expansion.
• The source from which the information was obtained.
• Records of our contact with you.
• Your marketing or contact preferences.

Sources may include:

• Companies House.
• Company and organisation websites.
• Professional networking profiles.
• Business directories.
• Public event or networking information.
• Publicly available social-media business pages.
• Professional referrals and introductions.

We do not intentionally collect private, unrelated or sensitive personal information for business-development outreach.

Information collected automatically

When you visit our website, we or our service providers may collect:

• Internet Protocol address.
• Browser type and version.
• Device type.
• Operating system.
• Pages visited.
• Date and time of visits.
• Referring website or source.
• General interaction and website-performance information.
• Cookie and similar-technology information.

Further information is provided in section 8.

Information received through third parties:

We may receive information through service providers used to operate Primavia, such as:

• Appointment and scheduling providers, such as Calendly.
• Email and mailing-list providers, such as Mailchimp.
• Website hosting and contact-form providers.
• Payment-processing providers.
• Event venues or booking providers.
• Professional advisers.
• People who refer or introduce you to us.

The information received will depend on the service and the choices you make when interacting with it.

3. How we use your personal data

We may use your personal information to:

• Respond to enquiries and communicate with you.
• Assess whether a Primavia product, event or service is suitable for you.
• Arrange consultations, meetings and events.
• Provide products, consulting services, workshops and events.
• Prepare for and personalise our work with you.
• Process bookings, payments, invoices and refunds.
• Manage our contractual relationship with you.
• Maintain appropriate client and business records.
• Provide service-related communications.
• Request feedback or testimonials.
• Improve our products, events, website and services.
• Monitor website security and technical performance.
• Send newsletters, resources or updates where you have subscribed.
• Conduct relevant and proportionate business-to-business outreach.
• Maintain records of marketing preferences and objections.
• Protect our legal rights and respond to disputes.
• Meet tax, accounting, regulatory and legal obligations.

We will never sell your personal information.

4. Lawful basis for processing

UK data-protection law requires us to have a lawful basis for using personal information.

Depending on the circumstances, we may rely on the following bases:

Purpose	Lawful Basis
Responding to an enquiry	Legitimate interests or taking steps at your request before entering into a contract
Assessing suitability for a service or event	Legitimate interests or taking steps before entering into a contract
Delivering products, events or consulting services	Performance of a contract
Managing bookings, payments and invoices	Performance of a contract and legal obligation
Maintaining tax and accounting records	Legal obligation
Providing service-related communications	Performance of a contract or legitimate interests
Improving our services and business operations	Legitimate interests
Protecting our website, systems and legal rights	Legitimate interests and, where applicable, legal obligation
Sending newsletters you have requested	Consent
Using non-essential cookies or analytics	Consent, where legally required
Conducting targeted B2B outreach	Legitimate interests
Maintaining a suppression or do-not-contact record	Legitimate interests and compliance with data-protection rights

Our legitimate interests

Where we rely on legitimate interests, those interests may include:

• Operating and developing Primavia.
• Promoting relevant products, services and events to appropriate business audiences.
• Identifying potential clients who may reasonably benefit from our services.
• Testing and validating demand for new offers.
• Communicating with people in a relevant professional capacity.
• Providing effective customer service.
• Improving our products, services and website.
• Protecting our systems, business and legal rights.
• Keeping an accurate record of people who do not wish to receive marketing.

We consider whether the use of your information is necessary and proportionate and whether your interests, rights or reasonable expectations override our interests.

Primavia maintains a Legitimate Interests Assessment for targeted Business Change Intensive outreach.

5. Business-to-business marketing and outreach

We may contact limited companies, limited liability partnerships and relevant business contacts to introduce Primavia services or events that appear reasonably relevant to their professional role or business.

For example, we may contact an owner or director of an established local business about the Business Change Intensive.

Where we use a named business contact’s professional information:

• We use only limited, business-relevant information.
• We identify ourselves and explain why we are contacting them.
• We do not conceal where reasonably practicable how we identified the business.
• We avoid making intrusive or unsupported assumptions about the person.
• We provide access to this Privacy Policy.
• We provide a straightforward way to object to further marketing.
• We maintain a suppression record where someone asks not to be contacted again.

We do not sell personal information or provide it to other businesses for their independent marketing.

Your right to object to direct marketing

You have an absolute right to object to the use of your personal information for direct marketing at any time.

To object, reply to any marketing email or contact: info@primaviaconsulting.co.uk

Once you object, we will stop using your information for direct marketing.

We may retain a minimal suppression record containing information such as your name, business email address and the date of your objection. This is used only to ensure that we continue to respect your request and do not accidentally contact you again.

6. Email newsletters and subscribed communications

Where you voluntarily subscribe to receive newsletters, resources or updates, we rely on your consent.

You can unsubscribe at any time by:

• Replying “UNSUBSCRIBE” to an email.
• Contacting info@primaviaconsulting.co.uk.

Unsubscribing from marketing will not prevent us from sending essential communications relating to a booking, contract, purchase or active service.

7. How long we keep your information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, including legal, tax, accounting and contractual requirements.

Our usual retention periods are:

Type of information	Usual retention period
General enquiries that do not become client relationships	Up to 12 months after the enquiry is closed
B2B prospect information where there is no response or relationship	Normally up to 6 months after the final outreach communication
Marketing suppression records	For as long as reasonably necessary to respect the objection
Mailing-list information	Mailing-list information Until you unsubscribe or the list is no longer used
Event attendee information	Normally up to 12 months after the event, unless needed for contractual, financial or legal records
Client and contractual records	Normally for the duration of the relationship and up to 6 years afterwards
Invoices, payments and financial records	For the period required by tax and accounting law
Testimonials	Until consent is withdrawn or the testimonial is no longer used
Website analytics	According to our cookie settings and the retention periods used by the relevant analytics provider

We may retain information for longer where:

• The law requires it.
• A dispute or legal claim exists or is reasonably anticipated.
• The information is needed to establish, exercise or defend legal rights.

We may anonymise information so that it can no longer identify an individual. Anonymised information may be retained for research, planning and statistical purposes.

8. Cookies

Cookies and website analytics

Our website uses cookies and similar technologies.

Cookies are small text files stored on your device when you visit a website. Some cookies are necessary for the website to function properly. Others help us understand how visitors use the website.

Essential cookies

We may use essential cookies that are necessary for the security, operation and basic functionality of the website.

These cookies do not require consent because the website may not work properly without them.

Google Analytics

We use Google Analytics 4, provided by Google, to understand how visitors use our website and to improve our content and services.

Google Analytics may collect information such as:

• Pages visited.
• Time spent on the website.
• How visitors reached the website.
• Approximate location.
• Device and browser type.
• General website interactions.

Google Analytics may set cookies including:

• _ga, which is used to distinguish website visitors.
• _ga_<property-id>, which is used to maintain session information for our Google Analytics property.

These cookies may remain on your device for up to two years.

Google Analytics cookies are not activated unless you choose Accept analytics through our cookie banner. You can reject analytics cookies or manage your preferences when you first visit the website.

You can change your choice at any time by selecting the Cookie settings control on the website.

We use Google Analytics information to produce aggregated reports and improve the performance, content and usability of the website. We do not use Google Analytics for advertising or behavioural profiling.

Managing cookies

Our website uses cookies and similar technologies.

Cookies are small text files stored on your device when you visit a website. Some cookies are necessary for the website to function properly. Others help us understand how visitors use the website.

Essential Cookies

We may use essential cookies that are necessary for the security, operation and basic functionality of the website.

These cookies do not require consent because the website may not work properly without them.

Google Analytics

We use Google Analytics 4, provided by Google, to understand how visitors use our website and to improve our content and services.

Google Analytics may collect information such as:

• Pages visited.
• Time spent on the website.
• How visitors reached the website.
• Approximate location.
• Device and browser type.
• General website interactions.

Google Analytics may set cookies including:

• _ga, which is used to distinguish website visitors.
• _ga_<property-id>, which is used to maintain session information for our Google Analytics property.

These cookies may remain on your device for up to two years.

Google Analytics cookies are not activated unless you choose Accept analytics through our cookie banner. You can reject analytics cookies or manage your preferences when you first visit the website.

You can change your choice at any time by selecting the Cookie settings control on the website.

We use Google Analytics information to produce aggregated reports and improve the performance, content and usability of the website. We do not use Google Analytics for advertising or behavioural profiling.

Managing Cookies

You can use our cookie banner to:

• Accept analytics cookies.
• Reject analytics cookies.
• Manage or change your preferences.

You can also delete or block cookies through your browser settings. Blocking essential cookies may affect how the website functions.

Further details about the cookies and services used on this website are available in our separate Cookie Policy.

9. How we share personal information

We may share limited personal information with trusted service providers where necessary to operate Primavia.

These may include:

• Website hosting and technical-support providers.
• Email and mailing-list providers.
• Scheduling and appointment-booking providers.
• Cloud storage and business-software providers.
• Payment processors and banking providers.
• Accountants, insurers and professional advisers.
• Event venues, caterers or delivery partners where necessary to administer an event.
• Contractors supporting the delivery of an agreed service.
• Government, regulatory, tax or law-enforcement bodies where required by law.
• Legal advisers, courts or other parties where necessary to establish, exercise or defend legal rights.

Service providers are permitted to use personal information only for the services they provide to us and must protect it appropriately.

We do not sell or rent personal information.

10. International transfers

Some of our technology or service providers may store or process information outside the United Kingdom.

Where personal information is transferred internationally, we take reasonable steps to ensure that an appropriate legal transfer mechanism is in place.

Depending on the destination and provider, this may include:

• UK adequacy regulations.
• An approved UK International Data Transfer Agreement.
• The UK Addendum to approved standard contractual clauses.
• Other safeguards permitted under UK data-protection law.

Further information about a particular provider or transfer can be requested by contacting us.

11. How we protect personal information

We use reasonable organisational and technical measures to protect information from unauthorised access, loss, misuse or disclosure.

These measures may include:

• Password-protected systems.
• Multi-factor authentication where available.
• Secure website hosting and HTTPS.
• Access restrictions.
• Data minimisation.
• Appropriate backups.
• Software updates and security patches.
• Secure cloud-storage providers.
• Limiting access to people who genuinely need the information.
• Reviewing and deleting information that is no longer required.

No internet or electronic-storage system can be guaranteed to be completely secure. However, we take reasonable precautions appropriate to the nature of the information we hold.

12. Your data protection rights

Depending on the circumstances, you may have the right to:

• Ask for access to the personal information we hold about you.
• Ask us to correct inaccurate or incomplete information.
• Ask us to delete your information.
• Ask us to restrict how information is used.
• Object to processing based on legitimate interests.
• Object to direct marketing at any time.
• Withdraw consent where processing is based on consent.
• Request the transfer of certain information in a portable format.
• Complain to the Information Commissioner’s Office.

Some rights are subject to legal conditions and exemptions. For example, we may need to retain certain financial records even after a deletion request.

We may need to verify your identity before responding to a request.

To exercise your rights, contact: info@primaviaconsulting.co.uk

13. Automated decision-making

Primavia does not currently use solely automated decision-making that produces legal or similarly significant effects.

We may use limited manual categorisation or segmentation to identify businesses that appear relevant to a particular service or event. Final outreach decisions are made by a person.

14. Children’s information

Primavia’s business and consulting services are intended for adults.

We do not knowingly collect personal information from children for marketing or consulting purposes. If we become aware that such information has been collected unnecessarily, we will delete it.

15. Third-party websites

Our website may contain links to websites or services operated by other organisations.

We are not responsible for the privacy practices of third-party websites. You should review their privacy policies before providing personal information.

16. Complaints

Please contact us first if you have concerns about how we use your information: info@primaviaconsulting.co.uk

You also have the right to complain to the Information Commissioner’s Office, the UK regulator for data protection.

Website: **https://ico.org.uk/make-a-complaint/**

17. Changes to this policy

We may update this Privacy Policy where our services, systems or legal obligations change.

The current version will always be published on this page. Significant changes may also be communicated through the website or directly where appropriate.