Privacy Policy

Wavelength Privacy Policy

Wavelength Companies Limited (company number: 06451333), Wavelength Inspire Limited (company number: 13083540), Wavelength Connect Limited (company number: 07088986), Wavelength Speakershub Limited (company number: 16039685) trading as Wavelength (“Us”, “We”, “Our”), is a limited company in the UK. Our registered address is Oakhurst, Chiltern Road, Ballinger, Great Missenden, Buckinghamshire, HP16 9LJ.

For the purposes of this policy, “you” refers to both you as an individual and, where applicable, your employer.

This policy is intended to give you an understanding of how and why we use the information you provide to us both online, through this website  wavelengthleadership.com (the “Website”) and otherwise. 

We respect your privacy and are committed to protecting your personal data We want to demonstrate this commitment to your privacy by informing you how we look after your personal data when you visit our Website. 

This Privacy Policy answers the following questions on your privacy rights and how the law protects you:

1. What information do we collect about you?
2. How is your personal data collected?
3. How will we use the information about you?
4. Marketing Communications
5. Will we share this information with others?
6. International transfers
7. How do we protect the security of personal data?
8. How long do we keep your data for?
9. Your privacy rights
10. How will we let you know of changes to our Privacy Policy?
11. How to contact us

Please read this policy carefully to understand how we will collect, use and store your data.

Wavelength Companies Ltd is the controller of your personal data and is responsible for your personal data. Questions regarding this Privacy Policy should be directed to Us by sending an email to [email protected]. Please write ‘Privacy Policy’ in the subject line.

1. What information do we collect about you?

This Privacy Policy aims to give you information on how We collect and process your personal data through your use of our Website. We collect personal data about you for a number of reasons, including communicating with you regarding our programmes, responding to requests for information, and to provide you with access to our resources.

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 your full name, username, profile name, personal meeting ID or similar identifier, passport details, travel insurance details, dietary and health requirements, profile photo, job title, marital status, title, date of birth and gender.
• Contact Data includes postal and/ or billing address, delivery address, email address and telephone numbers, preferred emergency telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes scripts, pixels and tags, 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, device ID and other technology on the devices you use to access this website. 
• Profile Data includes your username and password, purchases or orders made by you, content added to your profile for a Wavelength online event or programme, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you interact with and use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences, records of your correspondence with us, audio and/or visual recordings of Wavelength online events and programmes, information you may enter via email, text, the Website, Dropbox and GoogleDocs and other information you share with us.

We also collect information about the use of our website using cookies and similar tracking technologies (including tracking scripts, pixels, and tags). This includes recording page views, link clicks, video watch events, and dwell time. These tools help us understand how logged-in users engage with our services (such as the Inspire portal and Leadership Referral Circle), improve our offerings, and ensure site security. Some tracking events (such as clicks on links to files or external sites) may be recorded even if a pageview event is not triggered. We may also use analytics providers (e.g., Copper, Dropbox, Good Drive, Apple) and other third-party tools to process this information. 

There is also information about your computer hardware and software that is automatically collected by us. This technical information can include: your IP address (the unique identifying number of a computer), the browser you use, for example Internet Explorer, Firefox etc., domain names, access times and referring Website addresses. We use this information for the operation of the service, to maintain and improve the quality of the service, and to provide general statistics regarding use of the Website.

We (or our contractors and agents) may also photograph, video, or film (“image(s)”) you at our events (both our in-person and online events) and these images may identify you and therefore constitute personal data. We (or our contractors and agents) may use the images in any form of media, including the internet. We do this for marketing purposes including event promotion and product development and for the purpose of making our online events available to our members to watch on demand (where our members have paid for this service). In attending our events, you waive any and all right to notification, compensation, inspection or approval in relation to the image(s).

Please note that our 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.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

2. How is your personal data collected?

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

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 
  • apply for our services;
  • register as a Inspire Member;
  • create a Portal account on our website;
  • subscribe to get to latest news and marketing on our website;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• 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 data by using cookies, server logs, tracking scripts and other similar technologies. Please see our Cookies Notice for more information for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties such as Copper, Dropbox, Google Drive and Apple.

3. How will we use the information about you?

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

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 the various categories of 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.

4. Marketing Communications

We would love to keep you up to date with our services and resources. We will only do so where you have agreed to receive this information. We send the following types of marketing material:

• Updates about our programmes and events including newsletters and other publications;
• Relevant marketing communications and personalised suggestions and recommendations to you about products or services that may be of interest to you based on your Profile Data;
• Invitations to participate programmes and events; and
• Information about additional tools and resources which we think you might find interesting.

You can opt-out or update your communication preferences at any time by contacting us by sending an email to [email protected]. Please write ‘Opt Out’ in the subject line when contacting us in this way. Any electronic communications we send to you will have a link to unsubscribe from future electronic communications, so you can easily manage your own consent.

If you tell us you do not wish to receive marketing communications, you may still receive service-related communications that are essential for administrative or customer service purposes for example relating to Inspire Member registration, or registrations to our programmes. 

5. Will we share this information with others?

We do not share, sell or rent your information to third parties for marketing purposes. 

When using the Website to communicate with Wavelength members, certain information may be shared with them. This information may include profile information (for example your profile name and photo, your name and email address) and any information you choose to share when communicating with Wavelength members. 

We may share your personal data, where necessary, with the parties set out below for the purposes set out in the table above under ‘Purposes for which we will use your personal data’.

• Internal Third Parties: HR, Marketing, IT and Finance employees and associates 
• External Third Parties: group companies listed above, data sub-processors 
• Specific third parties listed 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.

6. International transfers

We may transfer your personal data to organisations that host, or support delivery of our programmes on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK such organisations, we may rely on derogations under Article 49 UK GDPR for specific transfers: 

• Article 49(1)(b) – the transfer is necessary for the performance of a contract with the data subject (for example, to deliver an overseas programme the individual has signed up to);
• Article 49(1)(c) – the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject.

Where we rely on these derogations, we provide the following information:

Recipients: At programme‑delivery level, when running events or tours in the United States, we may intermittently share personal data (such as contact details) with host organisations, hotels, tour operators and similar service providers that support the delivery of the programme so that we may perform our contract with you. 

Purpose and categories of personal data transferred: The transfer is necessary to facilitate the delivery of overseas programmes you have chosen to attend. Personal data shared may include: Identity data, Contact data, Transaction data, Profile data, Marketing and communications data. 

Risks associated with the transfer: Where the destination country does not benefit from an adequacy decision and contractual or other safeguards are not in place, your personal data may be subject to lower levels of legal protection, including:

• reduced data subject rights;
• limited supervisory authority oversight; and
• increased risk of access by public authorities without equivalent UK safeguards.

We only rely on such derogations where the transfer is occasional, necessary, and proportionate, and we take steps to minimise associated risks wherever possible.

Safeguards and how to access them: Where safeguards (such as contractual mechanisms) are used, copies can be requested by contacting us at [email protected]. 

Where a transfer occurs solely based on Article 49 derogations, we will only proceed with your explicit agreement, given at the point of event and/or programme registration.

Countries to which personal data is transferred: at present, the main third country to which we transfer personal data is the United States.

7. How do we protect the security of personal data?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data transferred via the internet. If you have any particular concerns about your information, please contact us.

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

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

8. How long do we keep your data for?

Data retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collect it for, including for the purposes of satisfying any legal, 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 requirements.

With regard to data collected as part of a programme or other event (e.g. dietary requirements and emergency contact details), our usual policy is that within six weeks of the end of the programme, such data is cleansed from computers, laptops, iPhones, iPads, Copper (our CRM system), Dropbox, GoogleDocs, and anywhere else it is stored. Any data that is recorded in hard copy is also securely disposed of. With regard tracking scripts and tracking data, we retain this data for a maximum of 6 months, after which it is automatically deleted.

Once you no longer have a relationship with us, we will retain and securely destroy your personal information in accordance with applicable laws and regulations. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see paragraph 10 below for further information.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

If you request to receive no further contact from us, we will keep some basic information about you on our suppression list in order to avoid sending you unwanted materials in the future.

9. Your privacy rights

You have a number of rights under data protection legislation. These include:

• Right of access

You have the right know what information we hold about you and to ask, in writing, to see your records. We will provide you with details of the records we hold as soon as possible and at latest within one month, unless the request is complex. We may require proof of identity before we are able to release the data. Please contact us by sending an email to [email protected] if you would like to exercise this right.

• Right to be informed

You have the right to be informed how your personal data will be used. This Privacy Policy as well as any additional information or notice that is provided to you either at the time you provided your details, or otherwise, is intended to provide you with this information.

• Right to withdraw consent

Where we process your data on the basis of your consent (for example, to send you marketing texts or e-mails) you can withdraw that consent at any time. To do this, or to discuss this right further with us, please contact us by sending an email to [email protected].  

• Right to object

You also have a right to object to us processing data where we are relying on it being within our legitimate interests to do so (for example, to send you direct marketing by post). To do this, or to discuss this right further with us, please contact us by sending an email to [email protected]. 

• Right to restrict processing

In certain situations you have the right to ask for processing of your personal data to be restricted because there is some disagreement about its accuracy or legitimate usage.

• Right of erasure

In some cases, you have the right to be forgotten (i.e. to have your personal data deleted from our database). Where you have requested that we do not send you marketing materials we will need to keep some limited information in order to ensure that you are not contacted in the future. Note, 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.

• Right of rectification

If you believe our records are inaccurate you have the right to ask for those records concerning you to be updated. To update your records please get in touch with us by sending an email to [email protected]. 

• Right to data portability

Where we are processing your personal data because you have given us your consent to do so, you have the right to request that the data is transferred from one service provider to another.

It is also 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.

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.

Complaints

If you are unhappy with the way in which we have handled your personal please get in touch with us by sending an email to [email protected]. 

You are also entitled to make a complaint to the Information Commissioner’s Office (“ICO”) (https://ico.org.uk) – however we would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

10. How will we let you know of changes to our Privacy Policy?

We keep this Privacy Policy under regular review and may update it from time to time without notice to you, so please check it regularly. We will however aim to bring any significant changes to your attention.

11. How to contact us

Please contact us if you have any questions about our Privacy Policy or information we hold about you:

By phone: + 44 (0) 7355 091 610
By e-mail: [email protected]. 

[1] Where we collect sensitive personal data about you, such as health information, we will normally only record this data where we have your explicit consent, unless we are permitted to do so in other circumstances under data protection law. For example, we may make a record that a person has particular access requirements.
[2] Again, we only use anonymised data in any resulting publication unless we have your explicit permission.