Privacy Policy

The Black Box Approach Limited PRIVACY POLICY 

1. Introduction The Black Box Approach Limited (“we”, “us”, “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and protect your personal data in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
2. What Data We Collect We collect personal data when you interact with our website, contact us, use our services, or engage with us as an employee, contractor, or supplier. This may include:

• Contact details (name, email, phone number, job title, organisation) 

• Payment information 

• Communications (emails, messages, and enquiries) 

• Service participation details (training, facilitation, or keynote sessions attended) 

• Website usage data (IP address, browser type, pages visited, time spent on site, referral source) 

• Cookies and tracking technologies 

• Employee and contractor data (payroll details, performance records, compliance documentation) 

• Supplier and partner data (business information, contact details, contract details) 

• Any other information you provide in relation to our services 

3. How We Use Your Data We use your personal data to:

• Deliver and manage our services 

• Communicate updates about our services 

• Process payments and invoices 

• Respond to enquiries and provide customer support 

• Improve our services through feedback and analytics 

• Comply with legal obligations 

4. Legal Basis for Processing We process personal data under the following legal bases:

• Contractual necessity – to provide services you have requested 

• Legitimate interests – to manage our business operations and improve services 

• Legal obligation – to comply with financial, tax, and regulatory requirements 

• Consent – where required, such as for marketing communications 

5. Data Sharing We do not sell or rent personal data. We may share personal data with:

• Service providers (e.g., payment processors, IT support, website analytics providers) who assist in service and website operations. 

• Legal and regulatory bodies when required by law. 

• Third-party marketing platforms, only if you have opted in to receive promotional communications. 

• Cloud storage and CRM system providers that securely process and store data, including those operating outside the UK, with appropriate safeguards in place. 

6. Data Retention We retain personal data only as long as necessary to fulfil the purposes outlined in this policy, comply with legal obligations, and resolve disputes. Generally, client records are retained for seven (7) years for tax and accounting purposes.
7. Data Security We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or misuse. In the event of a data breach affecting personal data, we will notify the Information Commissioner’s Office (ICO) and affected individuals within 72 hours where legally required.
8. Your Rights Under the UK GDPR, you have the right to:

• Access your personal data 

• Request correction of inaccurate data 

• Request deletion of your data where appropriate 

• Restrict or object to data processing 

• Withdraw consent for marketing at any time 

• Request data portability where applicable 

• Object to automated decision-making and profiling 

To exercise these rights, contact us at info@theblackboxapproach.com. 

9. Cookies and Website Tracking Our website uses cookies and similar tracking technologies to enhance user experience, analyse site traffic, and improve our services. Cookies may collect:

• Information about your device, browser, and IP address 

• Pages you visit and how you interact with the site 

• Referral sources (e.g., links clicked before arriving at our website) 

We may use third-party analytics tools, such as Google Analytics, to understand how visitors engage with our website. These tools may process data outside the UK, and we take appropriate measures to ensure compliance with data protection laws, including contractual safeguards where necessary. You can control cookie preferences via your browser settings. For more details, refer to our Cookie Policy. 

10. Changes to This Policy We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. Any significant changes will be communicated via email or a website announcement. The latest version will always be available on our website.

11. How to Make a Complaint If you have concerns about how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

Information Commissioner’s Office (ICO) Website: https://ico.org.uk/ Helpline: 0303 123 1113

12. Contact Us If you have any questions about this Privacy Policy or how we process personal data, please contact:

The Black Box Approach Limited
40 Bowling Green Lane, London, EC1R 0NE
0330 133 3733 | info@theblackboxapproach.com