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BACKGROUND

Trauma Thrivers and The VoyageŽ (Lebentz Consulting Ltd) understands that your privacy is important to you and that you care about how your personal data is used.

We respect and value the privacy of everyone who visits our websites, www.traumatrhivers.com or www.thevoyageacademy.com  (“The Sites”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested on using our websites.

DEFINITIONS AND INTERPRETATION

In this Policy the following terms shall have the following meanings:

“Account” This means an account is required to access and/or use certain areas and features of Our Sites;
“Cookie” This means a small text file placed on your computer or device by Our Sites when you visit certain parts or when you use certain features of Our Sites. Details of the Cookies used by Our Sites are set out in Part 14, below; and
“Cookie Law” This means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

INFORMATION ABOUT US

Our Sites are owned and operated by Trauma Thrivers and The Voyage Academy both trading names of Lebentz Consulting Ltd, a Private Limited Company registered in England under company number 09843248.

Registered address: Old Gunn Court, North Street, Dorking, Surrey, United Kingdom, RH4 1DE

Main trading address: Old Gunn Court, North Street, Dorking, Surrey, United Kingdom, RH4 1DE

VAT number: 387447155

Email address: [email protected].

Telephone number: +44 (0) 7789 866922

Postal address: Old Gunn Court, North Street, Dorking, Surrey, United Kingdom, RH4 1DE

WHAT DOES THIS POLICY COVER?

This Privacy Policy applies only to your use of Our Sites. Our Sites may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

WHAT IS PERSONAL DATA?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.


Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

WHAT ARE MY RIGHTS?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

  1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
  2. The right to access the personal data we hold about you. Part 13 will tell you how to do this.
  3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
  4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
  5. The right to restrict (i.e. prevent) the processing of your personal data.
  6. The right to object to us using your personal data for a particular purpose or purposes.
  7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
  8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided above.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed for as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details above.

WHAT DATA DO YOU COLLECT AND HOW?

Depending upon your use of Our Sites, we may collect and hold some or all of the personal and non-personal data set out below. Please also see the above for more information about our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data.

We collect personal data from the following types of people to allow us to undertake our business:

  • Prospective and live client contacts
  • Supplier contacts to support our services
  • Employees, consultants and temporary workers
Data Collected How We Collect the Data
Contact information including address, email address, and telephone numbers. Via our websites, when you correspond with us by phone, email or otherwise when you register your interest.
Contact information including email address, and telephone numbers. When you register your interest in receiving newsletters and other information.

HOW DO YOU USE MY PERSONAL DATA?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contracts, legal obligations and consent for specific uses of data.

We will rely on a contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.

We will rely on legal obligations if we are legally required to hold information about you only to fulfil our legal obligations. You will be notified about this request in advance.

LEGITIMATE INTERESTS

Be assured that we take your privacy seriously and will only use your personal information to administer your account and to provide you with the services that you have asked for.

MARKETING CONSENT

With your permission and/or where permitted by law, we will also use your personal data for marketing purposes, which will include contacting you by email with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt out.  We will always obtain your express opt-in consent and you will be able to opt out at any time.

Third Parties (including Google) whose content appears on Our Sites may use third-party Cookies, as detailed below. Please refer above for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details above.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

HOW LONG WILL YOU KEEP MY PERSONAL DATA?

We will not keep your personal data for any longer than is necessary for light of the reason(s) for which it was first collected. We will delete personal data from our systems if we have not had any meaningful contact with you for seven years.

HOW AND WHERE DO YOU STORE OR TRANSFER MY PERSONAL DATA?

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

  • Limiting access to your personal data to those employees and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
  • Procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;

DO YOU SHARE MY PERSONAL DATA?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
 

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

HOW CAN I CONTROL MY PERSONAL DATA?

In addition to your rights under the Data Protection Legislation, set out above and when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.

CAN I WITHHOLD INFORMATION?

You may access certain areas of Our Sites without providing any personal data at all. However, to use all features and functions available on Our Sites you may be required to submit or allow for the collection of certain data.

You may restrict Our Site’s use of Cookies. For more information, see the above section on cookies.

HOW CAN I ACCESS MY PERSONAL DATA?

If you want to know what personal data we hold about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in the contact details above.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 14 working days and, in any case, not more than one month after receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

HOW DO YOU USE COOKIES?

Our Sites may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Sites and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data are protected and respected at all times.

By using Our Sites, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Sites for Google Analytics and Social Media platforms. These Cookies are not integral to the functioning of Our Sites and your use and experience of Our Sites will not be impaired by refusing consent to them.
All Cookies used by and on Our Sites are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a pop-up prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Sites may not function fully or as intended.

Our Sites uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Sites is used. This, in turn, enables us to improve Our Site and the services offered through it.

The analytics service used by Our Sites use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however, whilst our use of them does not pose any risk to your privacy or your safe use of our sites, it does enable us to continually improve Our Sites, making it a better and more useful experience for you.

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however, you may lose any information that enables you to access Our Sites more quickly and efficiently including, but not limited to, login and personalisation settings.


It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

HOW DO I CONTACT YOU?

To contact us about anything to do with your personal data and data protection, including making a subject access request, please use the following details (for the attention of the Data Controller):

Email address: [email protected].

Telephone number: +44 (0) 7789 866922

Postal Address: Old Gunn Court, North Street, Dorking, Surrey, United Kingdom, RH4 1DE

CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on our sites and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 15/1/2023.