Privacy Policy

UnleashR Limited
Trading as UnleashR Consulting

Company Registration Number: 09189114
Registered Address: International House, 36-38 Cornhill, London, EC3V 3NG, United Kingdom

Last Updated: 9 September 2025

1. WHO WE ARE

UnleashR Limited is a UK registered company operating as UnleashR Consulting, providing business consulting services in operating model development, organisation design, business and organisational change management, and delivery management to small, medium, and large businesses in the UK and globally.

We also operate thrivePulse, an e-commerce brand offering digital and physical products directly to consumers. thrivePulse has its own dedicated website with separate privacy and other policies. If you are looking for information about thrivePulse, please visit the thrivePulse website directly.

We are the data controller for all personal data processed through our UnleashR Consulting business activities. This means we determine how and why your personal data is processed.

Contact Details:

• Primary website: unleashr-consulting.com

• Email domain: unleashr.co.uk

• Data Protection Officer: dpo@unleashr.co.uk

• Data Subject Requests: dpo@unleashr.co.uk

2. PERSONAL DATA WE COLLECT

2.1 UnleashR Consulting Services

We collect personal data necessary for delivering consulting services:

• Contact information: Names, email addresses, phone numbers, job titles, company details

• Professional information: Business requirements, project details, country of residence

• Communication records: Meeting notes, correspondence, project documentation

• Technical data: IP addresses, browser information, device identifiers, cookies (website visitors)

Note: While we may access personal details during consulting arrangements (such as employee data for organisational design projects), we do not store this information beyond the project duration unless specifically required for ongoing service delivery.

2.2 Website Visitors

• Analytics data: Page views, time on site, referral sources, geographic location

• Technical data: Browser type, device information, operating system

• Communication data: Contact form submissions, newsletter signups

3. HOW WE COLLECT YOUR DATA

We collect personal data through:

• Direct provision (forms, emails, phone calls, meetings)

• Website interactions and cookies

• Business partners and referrals

• Public sources (professional networks, company websites)

• Microsoft business tools and platforms

4. WHY WE USE YOUR DATA AND LEGAL BASIS

4.1 UnleashR Consulting

Purpose: Delivering consulting services

Legal Basis: Legitimate interests / Contract

Data Categories: Contact, professional, communication data

Purpose: Business administration

Legal Basis: Legitimate interests

Data Categories: Contact, professional data

Purpose: Legal Compliance

Legal Basis: Legal Obligation

Data Categories: All relevant data as required

Purpose: Fraud Prevention

Legal Basis: Legitimate Interests

Data Categories: Contact, professional data

Purpose: Website functionality and analytics

Legal Basis: Legal Obligation

Data Categories: Technical, analytics data

Legitimate Interests: Our legitimate business interests include providing professional consulting services, maintaining client relationships, business development, website improvement, and protecting our business from fraud. We have conducted legitimate interest assessments to ensure our processing is proportionate and does not override your rights and freedoms.

5. WHO WE SHARE YOUR DATA WITH

We share personal data with trusted third-party service providers who process data on our behalf:

5.1 Technology Providers

• Microsoft: Business operations, project management, email hosting, document storage

• UK subcontractors: May access personal data to support our consulting services

5.2 Other Recipients

• Legal and professional advisors: When required for legal compliance or business purposes

• Regulatory authorities: When legally required

We do not sell, rent, or trade your personal data to third parties. All third-party processors are bound by contractual obligations to protect your data and use it only for specified purposes.

6. INTERNATIONAL TRANSFERS

Given our global consulting operations, your data may be transferred outside the UK and European Economic Area (EEA) through our use of Microsoft services. When this occurs, we ensure appropriate safeguards are in place:

• Adequacy decisions: Transfers to countries deemed adequate by the UK government

• Standard contractual clauses: EU-approved contract terms ensuring data protection

• Provider certifications: Services certified under international privacy frameworks

All our consulting clients operate globally, but data transfers are managed through established service providers with appropriate safeguards.

7. HOW LONG WE KEEP YOUR DATA

We retain personal data only for as long as necessary for the purposes outlined in this policy:

7.1 Retention Periods

• Consulting client data: 6 years after project completion (for legal and business purposes)

• Website analytics: 26 months (aligned with standard analytics retention)

• Communication records: 3 years from last contact

• Legal compliance data: As required by applicable laws

7.2 Automatic Deletion

We regularly review and delete data that is no longer required. Some data may be anonymised for statistical analysis rather than deleted.

8. YOUR DATA PROTECTION RIGHTS

Under UK GDPR and the Data Protection Act 2018, you have comprehensive rights regarding your personal data:

8.1 Right to be Informed

What it means: You have the right to know how your personal data is being collected and used.

How we comply: This privacy policy provides comprehensive information about our data practices.

8.2 Right of Access (Subject Access Request)

What it means: You can request a copy of all personal data we hold about you.

How to exercise: Contact us at gpo@unleashr.co.uk with your request.

What you get:

• Confirmation of whether we process your personal data

• A copy of your personal data in a commonly used electronic format

• Information about how we use your data and who we share it with

• Details of your data protection rights

Timeframe: We will respond within one month.

8.3 Right to Rectification

What it means: You can ask us to correct inaccurate or incomplete personal data.

How to exercise: Contact us at gpo@unleashr.co.uk with details of the corrections needed.

8.4 Right to Erasure ('Right to be Forgotten')

What it means: You can request deletion of your personal data in specific circumstances.

When it applies:

• The data is no longer necessary for the original purpose

• You withdraw consent (where consent was the legal basis)

• You object to processing and there are no overriding legitimate grounds

• The data has been unlawfully processed

Limitations: We may refuse erasure if we need the data for legal compliance or defending legal claims.

8.5 Right to Restrict Processing

What it means: You can ask us to limit how we use your data in certain situations.

When it applies:

• You contest the accuracy of the data

• Processing is unlawful but you prefer restriction to erasure

• We no longer need the data, but you need it for legal claims

• You object to processing pending verification of our legitimate grounds

8.6 Right to Data Portability

What it means: You can obtain your personal data in a portable format to transfer to another service provider.

When it applies: Only when processing is based on consent or contract performance and processing is automated.

What you get: Your data in a structured, commonly used, machine-readable format.

8.7 Right to Object

What it means: You can object to certain types of data processing.

Direct Marketing: You have an absolute right to object to direct marketing at any time.

Legitimate Interests: You can object to processing based on our legitimate interests. We must stop processing unless we can demonstrate compelling legitimate grounds.

8.8 Right to Withdraw Consent

What it means: Where we process your data based on consent, you can withdraw that consent at any time.

Effect: Withdrawal doesn't affect the lawfulness of processing before withdrawal.

9. EXERCISING YOUR RIGHTS

9.1 How to Make Requests

Primary contact: dpo@unleashr.co.uk

What to include:

• Your full name and contact details

• Clear description of your request

• Identification verification (we may request additional ID to prevent fraud)

9.2 Our Response Process

• Acknowledgment: We'll acknowledge your request promptly

• Response time: Generally within one month

• Free of charge: Most requests are free

9.3 If We Cannot Comply

We'll explain why we cannot fulfill your request and inform you of your right to complain to the ICO.

10. COOKIES AND TRACKING

Our website uses cookies and similar technologies to:

• Enable website functionality

• Analyse website performance

• Remember your preferences

Cookie Categories:

• Essential cookies: Required for website operation (no consent needed)

• Analytics cookies: Help us understand website usage (consent required)

• Preference cookies: Remember your settings (consent required)

You can manage cookie preferences through our cookie banner or your browser settings. Note that blocking certain cookies may affect website functionality.

Detailed Cookie Information: For comprehensive information about specific cookies used, including duration and purposes, please refer to our separate Cookie Policy.

11. DATA SECURITY

We implement appropriate technical and organisational measures to protect your personal data:

• Encryption: Data is encrypted in transit and at rest

• Access controls: Limited access on a need-to-know basis

• Regular updates: Security systems are regularly updated

• Training: Staff receive data protection training

• Microsoft security: We leverage Microsoft's enterprise-grade security infrastructure

We will notify relevant authorities and affected individuals of any significant data breaches within 72 hours where required by law.

12. ACCESSIBILITY STATEMENT

12.1 Our Commitment to Accessibility

We are committed to ensuring that our website and services are accessible to everyone, regardless of ability or technology. We aim to conform to the Web Content Accessibility Guidelines (WCAG) 2.2 Level AA standards, which help make web content more accessible to people with disabilities.

12.2 How You Should Be Able to Use This Website

We want as many people as possible to be able to use this website. You should be able to:

• Change colours, contrast levels and fonts using browser or device settings

• Zoom in up to 400% without the text spilling off the screen

• Navigate most of the website using just a keyboard

• Navigate most of the website using speech recognition software

• Listen to most of the website using a screen reader (including recent versions of JAWS, NVDA and VoiceOver)

We also try to make the website text as simple as possible to understand.

If you have a disability, AbilityNet has advice on making your device easier to use.

12.3 How Accessible This Website Is

We work hard to ensure our website meets accessibility standards. However, we know that some parts of this website may not be fully accessible:

• Some PDF documents may not be fully accessible to screen reader software

• Some older content may not meet current accessibility standards

• Some interactive elements may be difficult to navigate using only a keyboard

12.4 What We're Doing to Improve Accessibility

We regularly review our website's accessibility and work to address any issues identified. This includes:

• Conducting regular accessibility audits

• Training our team on accessibility best practices

• Considering accessibility in all new website development

• Working with accessibility experts when needed

12.5 Feedback and Contact Information

If you need information on this website in a different format such as accessible PDF, large print, easy read, audio recording or braille, please contact us at gpo@unleashr.co.uk.

We'll consider your request and get back to you within 10 business days.

12.6 Reporting Accessibility Problems

We're always looking to improve the accessibility of this website. If you find any problems not listed above or think we're not meeting accessibility requirements, please contact us at gpo@unleashr.co.uk.

When reporting accessibility issues, please include:

• The web address (URL) of the content

• A description of the problem

• The assistive technology you were using (if applicable)

12.7 Enforcement Procedure

The Equality and Human Rights Commission (EHRC) is responsible for enforcing accessibility regulations. If you're not happy with how we respond to your complaint about accessibility, contact the Equality Advisory and Support Service (EASS).

13. CHILDREN'S PRIVACY

Our services are not intended for children under 16. We do not knowingly collect personal data from children under 16 without parental consent. If you believe we have collected such data, please contact us immediately at gpo@unleashr.co.uk.

14. CHANGES TO THIS POLICY

We may update this privacy policy periodically to reflect changes in our practices, technology, or legal requirements. We will:

• Post updates on our website with a clear indication of what has changed

• Notify you by email for significant changes (where we have your email address)

• Update the "Last Updated" date at the top of this policy

Continued use of our services after changes constitute acceptance of the updated policy.

15. COMPLAINTS AND FURTHER INFORMATION

15.1 Contact Our Data Protection Officer

If you have concerns about how we handle your personal data, please contact our Data Protection Officer at dpo@unleashr.co.uk.

15.2 Regulatory Complaints

If you remain unsatisfied, you have the right to lodge a complaint with the UK's data protection supervisory authority:

Information Commissioner's Office (ICO)

• Website: ico.org.uk

• Phone: 0303 123 1113

• Email: casework@ico.org.uk

• Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

16. CONTACT INFORMATION

Data Controller: UnleashR Limited

Business Inquiries: Via unleashr-consulting.com

Data Protection Matters:

• Data Protection Officer: dpo@unleashr.co.uk

• Data Subject Requests: dpo@unleashr.co.uk

Registered Address: International House, 36-38 Cornhill, London, EC3V 3NG, United Kingdom

Company Registration Number: 09189114

This privacy policy complies with UK GDPR, the Data Protection Act 2018, and incorporates relevant provisions from the Data (Use and Access) Act 2025. It reflects our commitment to protecting your personal data and providing transparency about our data practices. For specific legal advice regarding your data protection rights, please consult with a qualified legal professional.

Cookie Policy

UnleashR Limited
Trading as UnleashR Consulting

Company Registration Number: 09189114
Registered Address: International House, 36-38 Cornhill, London, EC3V 3NG, United Kingdom

Website: unleashr-consulting.com
Last Updated: 9 September 2025

1. WHAT ARE COOKIES?

Cookies are small text files that are placed on your device (computer, smartphone, tablet) when you visit our website. They are widely used to make websites work more efficiently and to provide a better browsing experience.

This Cookie Policy explains how we use cookies and similar technologies on our website, what types of cookies we use, the purposes for which we use them, and how you can manage your cookie preferences.

2. WHAT COOKIES DO WE USE?

Currently, our website unleashr-consulting.com uses a minimal approach to cookies. The website is built using Hostinger Website Builder and primarily uses only essential cookies necessary for basic website functionality.

2.1 Essential Cookies (No Consent Required)

These cookies are strictly necessary for the website to function and cannot be switched off. They are usually only set in response to actions made by you which amount to a request for services.

Cookie Name: Form Data Storage

Provider: Hostinger

Purpose: Temporarily stores form data when you submit enquiry forms (name, email, phone number) to prevent data loss

Duration: Session/Until form submission

More Information: Essential for contact form functionality

Cookie Name: Session Management

Provider: Hostinger

Purpose: Maintains your session while browsing the website

Duration: Session (until browser closed)

More Information: Basic website functionality

Cookie Name: Security Cookies

Provider: Cloudflare (via Hostinger)

Purpose: Protects against security threats and ensures secure connection

Duration: Various durations

More Information: Website security and performance

Note: Essential cookies do not require your consent under UK law as they are strictly necessary for the website to function.

2.2 Analytics (Cookie-Free)

Hostinger Website Builder Analytics: Our website uses Hostinger's built-in analytics tool to understand website traffic and visitor patterns. Importantly, this analytics tool:

• Does not use any cookies

• Does not collect personal data

• Operates through Cloudflare CDN without third-party integrations

• Does not require visitor consent

• Is not shared or connected with other websites

This cookie-free analytics provides us with basic traffic overview information such as:

• Number of website visits

• Geographic regions of visitors (country level only)

• Device types (desktop vs mobile)

• Most visited pages

As this analytics tool does not use cookies or collect personal data, it does not require mention in privacy policies under GDPR and PECR regulations.

2.3 Cookies We Do NOT Use

Our website does not currently use:

• Marketing or advertising cookies

• Social media cookies

• Third-party tracking cookies

• Google Analytics or other third-party analytics

• Personalization cookies

• Targeting or remarketing cookies

3. LEGAL BASIS FOR COOKIE USE

3.1 Essential Cookies

We use essential cookies on the legal basis of legitimate interests under UK GDPR Article 6(1)(f). Our legitimate interest is to ensure the basic functionality and security of our website, which is necessary for providing our consulting services information to visitors.

3.2 Analytics (Cookie-Free)

As our analytics tool does not use cookies or collect personal data, no legal basis under GDPR is required for data processing.

4. THIRD-PARTY COOKIES

4.1 Cloudflare (Security and Performance)

Our website hosting through Hostinger utilizes Cloudflare's Content Delivery Network (CDN) for security and performance optimization. Cloudflare may set essential cookies for:

• Security protection against malicious attacks

• Load balancing to optimize website performance

• DDoS protection and threat mitigation

These are considered essential cookies for website security and performance.

Cloudflare Privacy Policy: https://www.cloudflare.com/privacypolicy/

4.2 Hostinger Platform

As our website is built on Hostinger Website Builder, Hostinger may set essential cookies for:

• Platform functionality and website builder operations

• Form processing for enquiry submissions

• Session management during website visits

Hostinger Privacy Policy: https://www.hostinger.com/legal/privacy-policy

5. COOKIE MANAGEMENT AND YOUR CHOICES

5.1 Browser Settings

You can control cookies through your browser settings. Most browsers allow you to:

• View cookies that have been set on your device

• Delete cookies from your device

• Block cookies from being set

• Set preferences for different types of cookies

Please note: Blocking essential cookies may affect the functionality of our website, particularly the enquiry form submission process.

5.2 How to Manage Cookies in Different Browsers

Google Chrome:

1. Click the three-dot menu → Settings → Privacy and Security → Cookies and other site data

2. Choose your preferred cookie settings

Mozilla Firefox:

1. Click the menu button → Settings → Privacy & Security

2. Under "Cookies and Site Data," choose your settings

Safari:

1. Go to Safari → Preferences → Privacy

2. Choose your cookie and tracking preferences

Microsoft Edge:

1. Click the three-dot menu → Settings → Cookies and site permissions

2. Manage your cookie settings

5.3 Current Cookie Requirements

Since our website currently only uses essential cookies and cookie-free analytics, no cookie consent banner is required under UK PECR regulations. Essential cookies are exempt from consent requirements as they are strictly necessary for website functionality.

6. FUTURE COOKIE USE

Should we decide to implement additional cookies in the future (such as marketing cookies, third-party analytics, or social media integrations), we will:

1. Update this Cookie Policy with details of new cookies

2. Implement a cookie consent banner where required by law

3. Obtain your consent before setting non-essential cookies

4. Provide clear information about cookie choices and management options

5. Notify existing users of significant changes to our cookie practices

7. CONTACT FORM DATA PROCESSING

When you submit our enquiry form, we collect:

• Name - to identify and respond to your enquiry

• Email address - to provide our response

• Phone number - for alternative contact if preferred

• Enquiry details - to understand your consulting needs

This information is:

• Stored securely on Hostinger's servers

• Used solely for responding to your business enquiry

• Not shared with third parties except as necessary to respond to your enquiry

• Retained for legitimate business purposes as outlined in our Privacy Policy

• Processed under the legal basis of legitimate interests for business enquiry handling

8. COMPLIANCE WITH UK LAW

This Cookie Policy complies with:

• Privacy and Electronic Communications Regulations (PECR) 2003

• UK General Data Protection Regulation (UK GDPR)

• Data Protection Act 2018

• Data (Use and Access) Act 2025

8.1 Lawful Basis Summary

Cookie Type: Essential Cookies

Legal Basis: Legitimate Interests (UK GDPR Article 6(1)(f))

Consent Required: No

Cookie Type: Cookie-Free Analytics

Legal Basis: Not applicable (no personal data processed)

Consent Required: No

Cookie Type: Security Cookies

Legal Basis: Legitimate Interests (website security))

Consent Required: No

9. CHANGES TO THIS COOKIE POLICY

We may update this Cookie Policy from time to time to reflect changes in our cookie practices, technology, or legal requirements. When we make changes, we will:

• Update the "Last Updated" date at the top of this policy

• Post the updated policy on our website

• Notify users by email for significant changes (where we have email addresses)

• Implement appropriate consent mechanisms if new non-essential cookies are introduced

We recommend that you review this Cookie Policy periodically to stay informed about our cookie practices.

10. CONTACT INFORMATION

If you have any questions about our use of cookies or this Cookie Policy, please contact us:

Data Protection Enquiries: dpo@unleashr.co.uk
General Business Enquiries: Via the contact form on unleashr-consulting.com

Postal Address:
UnleashR Limited
International House
36-38 Cornhill
London, EC3V 3NG
United Kingdom

Company Registration Number: 09189114

11. REGULATORY INFORMATION

11.1 Data Protection Authority

If you have concerns about our cookie practices that we cannot resolve, you can contact the UK's data protection supervisory authority:

Information Commissioner's Office (ICO)
Website: ico.org.uk
Phone: 0303 123 1113
Email: casework@ico.org.uk

11.2 Your Rights

Under UK data protection law, you have rights regarding any personal data we process through cookies, including:

• Right to be informed (provided through this policy)

• Right to access your data

• Right to rectification

• Right to erasure

• Right to object to processing

For full details of your rights, please see our Privacy Policy.

This Cookie Policy is designed to comply with UK PECR, UK GDPR, and the Data Protection Act 2018. Given our minimal use of essential cookies only, we currently operate under the "strictly necessary" exemption that does not require user consent. Should our cookie practices change to include non-essential cookies, we will implement appropriate consent mechanisms and update this policy accordingly.